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Avon Metals “Our 20/20 Vision” 2010 Sustainability Report

2010 Sustainability Report - CEO Water Mandate · 2010 Sustainability Report. C O N T E N T S INTRODUCTION PAGES 3 -4 ENVIRONMENTAL DIMENSION ... Chloride (as HCl) –permissible

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Page 1: 2010 Sustainability Report - CEO Water Mandate · 2010 Sustainability Report. C O N T E N T S INTRODUCTION PAGES 3 -4 ENVIRONMENTAL DIMENSION ... Chloride (as HCl) –permissible

Avon Metals

“Our 20/20 Vision”

2010 Sustainability Report

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INTRODUCTION PAGES 3 - 4

ENVIRONMENTAL DIMENSION

SDI 1 REDUCTION OF GREENHOUSE GASES PAGES 5 - 9

SDI 2 REDUCTION IN ELECTRICAL ENERGY PAGE 10

SDI 3 TRANSPORT MANAGEMENT PAGE 10

SDI 4 ENVIRONMENTAL MANAGEMENT SYSTEM PAGE 11

SDI 5 IMPLIMENTATION OF REACH REGULATION PAGE 11

SDI 6 SOURCING OF SUSTAINABLE RAW MATERIALS PAGE 12

SDI 7 NOISE REDUCTION PAGE 12

SDI 8 REDUCTION IN THE AMOUNT OF PACKAGING WASTE GOING TO LANDFILL PAGE 13

SDI 9 DEVELOPING A RECYLING STRATEGY (INCLUDING SAFE DISPOSAL OR RE-USE

OF WASTE PRODUCTS)PAGE 14

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OF WASTE PRODUCTS)

SDI 10 PROTECTION OF LOCAL WILDLIFE & PROMOTION OF BIODIVERSITY PAGE 15

SDI 11 REDUCTION OF FRESHWATER CONSUMPTION PER TONNE OF ALUMINIUM

PRODUCED & RAINWATER CAPTURE (INCLUDING UNITED NATIONS WATER COP)PAGES 16 - 22

SOCIAL DIMENSION

SDI 12 HEALTH 7 SAFETY – REDUCTION IN WORKPLACE INJURIES PAGES 23 – 27

SDI 13 STAFF TRAINING AND PERSONAL DEVELOPMENT PAGES 28 – 30

SDI 14 IMPROVEMENT & DEVELOPMENT OF COMMUNITY RELATIONS PAGES 31 – 33

SDI 15 UNITED NATIONS GLOBAL COMPACT SIGNATORY PAGES 34 – 38

SDI 16 HUMAN RIGHTS (INCLUDING DEVELOPING AN ANTI-BRIBERY AND ANTI

CORRUPTION INITIATIVE)PAGES 39 – 42

ECONOMIC DIMENSION

SDI 17 PRODUCT STEWARDSHIP (INCLUDING PRODUCT LIFE CYCLE ASSESSMENT) PAGES 43 - 46

SDI 18 FINANCIAL CONTRIBUTION TO THE LOCAL ECONOMY PAGE 47

SDI 19 RESEARCH & DEVELOPMENT PAGE 48

SDI 20 GLOBAL REPORTING INITIATIVE PAGES 49 - 70

MANAGEMENT & LEADERSHIP PAGE 71

STAKEHOLDER ENGAGEMENT – BRIDGING THE GAP PAGES 72- 74

KEY FACTS & FIGURES PAGE 75

AWARDS & ACCREDITATIONS PAGE 76

ORGANISATIONAL CHART PAGE 77

CONTACT DETAILS PAGE 78

GRI APPLICATION LEVEL CHECK STATEMENT PAGE 79

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EXECUTIVE SUMMARY

Avon Metals is a metals recycling company whose main activity is the production

of 10,000 metric tonnes per annum of primary and secondary (scrap) based

aluminium alloys in ingot form. These ingots are used by producers of aluminium

products to ultimately make a wide range of everyday products. These include;

beverage cans; pie case foil; car engines & wheels; aircraft engines and landing

gear; building products - such as door and window frame extrusions and curtain

walling.

The Company is also an important physical trader of various other primary,

secondary (scrap) and specialty minor metals (including titanium and tungsten).

Following a major restructuring and an increase in international trade, the

company has prospered into a dynamic, forward thinking business that has been

recognised in local and national business awards, including a Queen’s Award for

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 3

recognised in local and national business awards, including a Queen’s Award for

Enterprise in Sustainable Development in 2009, and 2 Major Commendations in

the 2010 BCE Environmental Leadership Awards & EEF Future Manufacturing

Awards.

Avon Metals has demonstrated that a pragmatic approach to investing in our

people, and protecting the environment through sustainable development, can

be commercially viable.

Our 20/20 Vision Sustainability Report aims to deepen our Stakeholders’

understanding about Avon Metals Corporate Social Responsibility Activities.

MISSION STATEMENT

“Our mission is to be recognised as the best metal recycling company in the

world. We strive to provide consistently attractive returns to our shareholders

through best available techniques, sustainable development and good

corporate citizenship.”

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INTRODUCTION TO OUR SUSTAINABILITY PHILOSOPHY

Sustainability, or sustainable development, is often defined as acting in a manner

that meets the needs of today without hindering future generations.

Back in 2006, Avon Metals made a conscious decision to embark on a pioneering

journey towards implementing, measuring and reporting sustainability.

Sustainability is more than just an initiative for Avon Metals - it is a philosophy that

permeates right through the company influencing every single activity and decision.

Avon Metals is committed to this philosophy and to continuous improvement on our

road towards total sustainability.

We seek to create a world class brand that will motivate customers, employees,

suppliers and communities to partner with us for mutual long term benefit.

To achieve this, Avon has developed an all-encompassing, innovative Management

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 4

To achieve this, Avon has developed an all-encompassing, innovative Management

and Leadership System entitled "Our 20/20 Vision". This initiative is based around

20 voluntary, quantitative Sustainable Development Indicators (SDI), covering the

company’s key performance in all three pillars of sustainable development – social

well-being, economic prosperity and environmental stewardship - to be

systematically measured and transparently reported to our stakeholders.

In its pursuits to achieve sustainability, Avon has cultivated new markets and forged

new partnerships in a diverse array of market sectors ranging from aerospace and

automotive, to alternative renewable energy sources and commercial applications

for our process residues.

Progress is benchmarked against realistic internal and external business targets.

Reliable measurement is essential to guarantee continued monitoring, careful

evaluation, committed implementation and tangible results. These are the

cornerstone principles behind Avon Metals SDI reporting and we are determined to

grow in ways that ensure a sustainable future for generations to come.

Continuous improvement is our aim, and to this end we have adopted a Kaizen

philosophy. Input from stakeholders & shareholders alike will be actively sought and

encouraged to ensure that we continue to implement best practices. We strive to

exceed stakeholder expectations and improve the quality of life through our

products and actions, and we will communicate transparently our vision, objectives

and performance.Steven Munnoch,, Managing

Director

January 2011

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SUSTAINABLE DEVELOPMENT INDICATOR (SDI) 1

REDUCTION OF GREENHOUSE GASES

Avon Metals has invested over £500k in plant and equipment to protect the

environment. A state-of-the-art fume arrestment plant has made significant

reductions to carbon emissions. It is our aim to become Carbon Neutral by 2020 and

the company is working with the Carbon Neutral Company to achieve this. Whenever

Company representatives travel overseas, we select to offset our carbon emissions

when booking flights.

The Company is an active member of the Climate Change Levy scheme operated by

the DTI. Through investment in new, more energy efficient plant and equipment we

have reduced our CO² emissions by an estimated 93% our Carbon Monoxide emissions

by 39% in the reporting period 2006-2010. Our other Air Emission levels are well

below the statutory levels imposed under our Permit to Operate. The table below

details our Gas Emission Levels.

Direct

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Gas Emission

Direct

Greenhouse Gas

/ Indirect

Greenhouse Gas

/ Other Air

Emission

2006

Emissions

(mg/m3)

2007

Emissions

(mg/m3)

2008

Emissions

(mg/m3)

2009

Emissions

(mg/m3)

2010

Emissions

(mg/m3)

Carbon Dioxide (CO2) Direct 31 15.8 2.38 2.38 2.38

Methane

Hydrofluorocarbons (HFCs)

Petrofluorocarbons (PFCs)

Sulphur Hexafluoride (SF6)

Direct Avon Metals is not a significant generator of these Direct Greenhouse Gases

Nitrogen Oxide (NOx) Direct 31 <5 2.28 2.28 2.28

Sulphur Dioxide (SOx) DirectData collection

started in 20074.1 2.9 2.9 2.9

Carbon Monoxide (MO) IndirectData collection

started in 20073.9 2.38 2.38 2.38

Non-methane volatile organic compounds

(NMVOCs)Indirect Avon Metals is not a significant generator of these Indirect Greenhouse Gases

Cadmium and its compounds OtherData collection

started in 20070.007 0.015 0.015 0.015

Lead and its compounds – permissible max.

limit = 1 mg/m3Other

0.100.018 0.010 0.010 0.010

Chloride (as HCl) – permissible max. limit = 5

mg/m3Other 2.19 1.08 1.38 1.38 1.38

Fluoride (as HF) – permissible max. limit = 5

mg/m3Other 0.23 0.14 0.430 0.430 0.430

Total particulate matter – permissible max.

limit 20 mg/m3Other 9.47 2.62 3.605 3.605 3.605

Chlorofluorocarbons (CFCs) Other Avon Metals is not a significant generator of these other ozone depleting substances.

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SDI 2

REDUCTION OF GREENHOUSE GASES CONTINUED...

Avon Metals Corporate Carbon Neutral Strategy

Avon Metals is a forward thinking, environmentally conscious company, and we

have made a pledge to reduce our carbon footprint an ultimate target of becoming

“carbon neutral”.

Following the recent economic downturn, our carbon neutral target has been

revised to 2020. A planned power correction upgrade at a cost of £130k plus

installation costs has been rescheduled for 2012, and will save in excess of 1000

tonnes per annum of CO² emissions alone.

Being carbon neutral involves calculating the total climate-damaging carbon

emissions, reducing them where possible, and then balancing the remaining

emissions, often by purchasing a carbon offset e.g. paying to plant new trees or

investing in “green” technologies such as solar and wind power.

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investing in “green” technologies such as solar and wind power.

Our strategy therefore involves the implementation of three basic steps –

Measure, Reduce, Offset.

1 - MEASURE

Measure Avon’s footprint by inventorying the greenhouse gas emissions we

generate Avon Metals uses the post-Kyoto agreement Greenhouse Gas Protocol

(GHG Protocol) accounting framework to understand, quantify, and manage our

emissions to the environment.

In 2006-2009, Avon Metals average annual carbon footprint was calculated at

5,070.64 tonnes of Carbon Dioxide per annum, broken down as follows: -

• Electricity 3,222 tonnes CO²

• Gas 1,632 tonnes CO²

• Heating Oil 120.63 tonnes CO²

• Company Owned Vehicles 31.82 tonnes CO²

• Business Travel 15.96 tonnes CO²

• Commuting 6.94 tonnes CO²

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2 - REDUCE

Develop targeted goals and strategies for Reducing those emissions.

Setting the boundaries for measurement

There are three categories of emissions generated in the course of conducting

business. These delineations referred to in the GHG Protocol were developed in order

to avoid future double counting.

Scope 1 (Direct Emissions)

Those emissions that are generated from on-site production or direct combustion of

fossil fuels through Avon-owned facilities, vehicles and equipment.

Scope 2 (Indirect Emissions – electricity consumption)

Those emissions that are generated through the consumption of electricity (kWh) to

SDI 1

REDUCTION OF GREENHOUSE GASES CONTINUED...

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Those emissions that are generated through the consumption of electricity (kWh) to

light and power offices and operations.

Scope 3 (Other Indirect Emissions)

Includes all the other activities that move products or services to market or the

community. This list of indirect emissions includes business travel, employee

commuting, outsourced activities (shipping, printing) and third party produced

materials used such as paper and equipment.

A survey conducted by the Carbon Trust highlighted areas of improvements to

reduce our Carbon Footprint and the Avon Metals has already implemented

many of the recommendations made (see table to the left). This survey has

helped us prioritise known savings as well as identifying new opportunities.

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SDI 1

REDUCTION OF GREENHOUSE GASES CONTINUED...

AVON METALS CARBON BALANCE

Carbon Footprint Tonnes CO2 Totals

Electricity 3222

Gas 1632

Oil (heating and plant) 120

Waste 41

Business travel 16

Company Vehicles 32

Commuting 7

Total Current Carbon Footprint 5070

Actions Implemented to reduce above

Raw material savings 50% as some indirect 1416

Burner Efficiency 300

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Monitoring and efficiency of energy use 234

Switch off lights 3

Replacing floodlights 4

Repaired air leaks 15

Passive IR light controls 2

Idle casting tracks 14

Extractor fan variable speed drives 52

Local sourcing 5

Consolidated transport fleet 5

Environmental/energy bonuses 1

Office and works recycling 1

Aluminium pallets to replace wooden 56

Flight offsetting 6

Tree Planting work through Alupro 10

Total current Carbon Reductions 2124

Future Plans

Power correction 1000

Conference calls 2

Car sharing 1

WWT carbon sink 500

Installing Energy Star Equipment 130

Biomass boiler 150

Glos wildlife and other Biodiversity actions 100

Carbon Trust extra savings 200

Projected Future Carbon Savings 2083

Nett Carbon to Offset 863

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3 – OFFSET

Net to zero the remaining annual emissions generated by purchasing Offsets, when

there is no other viable way of reducing.

Offsetting provides a mechanism to reduce GHG emissions in the most cost-effective

and economically-efficient manner. Offsetting plays a vital role in combating climate

change, but it is not alone, the solution.

Avon Metals belief is that climate change will only be addressed if each and every one

of us takes responsible steps to REDUCE our CO2 emissions as much as possible and

offset the remaining unavoidable emissions.

We will mitigate our surplus carbon dioxide emissions by investing in projects that

avoid or absorb an equivalent amount of greenhouse gases from entering the

SDI 1

REDUCTION OF GREENHOUSE GASES CONTINUED...

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 9

avoid or absorb an equivalent amount of greenhouse gases from entering the

atmosphere.

There are three types of carbon offset projects:

• Renewable energy Projects - (wind, solar, geothermal, small hydro and biomass)

that avoid future carbon emissions by displacing fossil fuels.

• Energy efficiency Projects - that reduce demand through low energy lighting,

retrofits, green buildings and industrial energy efficiencies.

• Carbon Sequestration Projects – which protect or increase capacity of forest

ecosystems by avoiding deforestation, restoration and reforestation.

Avon Metals may choose to take a “portfolio” approach: invest in one or all of these

projects. We will continue to partner with Slimbridge Wildfowl and Wetlands Trust on

various projects aimed at protecting and nurturing Wetland areas which act as a

natural “carbon sink” and help to offset our carbon emissions; reed beds naturally

detoxify sewage water before it enters local river systems, wetlands help combat

flooding –the risk being demonstrated by the 2007 Gloucestershire floods; many

other “ecosystem services” and anthropocentric benefits that are often not readily

visible, including: -natural regulation of air quality, pollination and biological pest

control.

When we have completed our plans and feel that we can do no more – then, and only

then – will we resort to buying carbon credits to offset the remainder.

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SDI 2

REDUCTION IN ELECTRICAL ENERGY

The commissioning of a new gas fired reverberatory furnace that uses organic

material, such as paint and plastic backing, as a catalyst to fuel the melting process,

has helped reduce our total energy consumption by 0.08 Mwh per tonne of finished

product - a 5% overall decrease within the application period.

Every year Avon Metals trades a large amount of Silicon metal into the photovoltaics

industry for the production of silicon wafers for solar panels - a renewable energy

source, and one which we intend to fully exploit.

Future plans also include looking at the possibility of harnessing the heat generated by

our furnace chimney stack via a turbine system to power the heating system in our

office block.

SDI 3

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SDI 3

TRANSPORT MANAGEMENT

Avon delivers finished ingots to UK customers and operates a skip collection service

for industrial generators of aluminium scrap. These movements have always required

the use of three vehicles – a curtain-side lorry and two skip wagons. By investing in a

new truck with an innovative, versatile loading system that can incorporate both

finished product and loose scrap, we have been able to consolidate our transport from

3 vehicles into 1. Not only does this reduce our internal transport costs per tonne, it

also makes for more effective route planning by maximising payloads and therefore

reduces our Carbon Footprint through conserved fuel and lower emissions.

Unfortunately, the recent hike in fuel prices has meant that this positive initiative on

our behalf has been somewhat negated.

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SDI 4

ENVIRONMENTAL MANAGEMENT SYSTEM

The Company is accredited to the Environmental Management System (EMS) ISO

14001. The following is controlled under this Standard: -

�Monitoring emissions to the atmosphere from chimney stacks.

�Monitoring noise levels – to neighbouring businesses, residential areas and also

to our workforce.

� Recycling of aluminium packaging waste.

�Waste minimisation and appropriate disposal for recycling/reprocessing and

reprocessing of waste by products such as dross, wood, building materials, toner

cartridges, mobile phones, paper, cardboard & plastics.

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cartridges, mobile phones, paper, cardboard & plastics.

� Safe management and disposal of effluents.

SDI 5

IMPLIMENTATION OF REACH REGULATION

We support REACH, the pan-European legislation for the Registration, Evaluation and

Authorisation of Chemicals. The aim of REACH is to protect people’s health and the

environment through a risk assessment of chemicals produced in the European

Community. We see REACH not as a threat but as a business opportunity and we

have pre-registered all eligible substances we handle .

We are a Gold Member of Reach Ready – a wholly owned subsidiary of the Chemicals

Industries Association

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SDI 6

SOURCING OF SUSTAINABLE RAW MATERIALS

A large proportion of the aluminium alloys that Avon manufactures involve the use

of high purity (99.5% min) aluminium. This has predominantly been achieved by re-

melting virgin aluminium ingots produced from alumina (bauxite). Through

extensive overseas travel, Avon identified new sources of scrap with similar

chemistry to primary ingots, but with an associated cost advantage to us. One good

example of this type of scrap is heat shields that are normally destined for car

engines. Material has been successfully bought on long term contracts from South

Africa, Spain and the Antipodes. In 2006 -2010, we replaced over 2500 metric

tonnes per annum of primary ingot with new production scrap, reducing the need

to buy material mined directly from ore and saving 95% of the energy required to

refine the ore into primary ingots. The associated cost saving to the business over

these two years is estimated at £430k. Our overall recycling input materials rate

increased from 70% to 76% in the period of reporting.

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increased from 70% to 76% in the period of reporting.

SDI 7

NOISE REDUCTION

During the period of application, Avon installed louvered windows at high level in

the foundry to cut down on noise emissions from plant and equipment. Noisy

oxygen enrichment equipment was de-commissioned and replaced with quieter

burner systems. The height of our boundary tree screening was also increased to

further dampen noise pollution and to promote the nesting of birds and other

important wildlife.

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SDI 8

REDUCTION IN THE AMOUNT OF PACKAGING WASTE GOING TO LANDFILL

Aluminium packaging waste is sourced on a local and national scale. Recent

investment in plant and equipment through revenue gained from the sale of

Packaging Recovery Notes (PRN) has enabled the Company to widen the range of

aluminium scrap it handles and the amount of packaging waste it reprocesses. Two

1.5 tonne induction furnaces, which were commissioned at the start of 2006, have

made it possible for Avon to take in, melt and recycle a more diverse range of raw

materials, including foils. The company has also invested in a fume extraction plant

for the melting of decorated and lacquered aluminium - toothpaste tubes, for

example – which emit more smoke due to the organic content. In 2006 we received

an award from the Compliance Scheme - Valpak - for Best Investment of PRN

Revenue

In the period 2006-2010 we recycled 3237 tonnes of aluminium packaging waste

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In the period 2006-2010 we recycled 3237 tonnes of aluminium packaging waste

into new useful products, that would otherwise have gone down the landfill or

incineration routes.

Our corporate membership of Alupro (the non-profit Aluminium Packaging

Recycling Organisation) encourages charity groups based in and around

Gloucestershire to sort aluminium foil from waste streams and bring to Avon for

remelting. These groups (such as the Fairtide Centre in Lydney, the Cheltenham

Integrated Recycling Project and the Oakley Adult Opportunity Centre in Whaddon)

provide meaningful voluntary work for severely disabled people who sort the foil.

These schemes help disabled people build self-esteem and realise their true

potential. As a result, the community is challenged to change their perceptions

about disabled people. Income generated from the sale of the foil to is reinvested

into the project which has full involvement of Alupro and support from Vision 21

(Cheltenham) and Cheltenham Centre for Change.

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SDI 9

DEVELOPING A RECYLING STRATEGY (INCLUDING SAFE DISPOSAL OR RE-USE OF

WASTE PRODUCTS)

Avon Metals is ultimately an aluminium recycling company. Aluminium can, with just

cause, be described as the “green” metal. Aluminium meets the complex ecological

and technological requirements of our environmentally conscious society, and is a

considerable ally in the fight against waste, energy consumption and environmental

damage. The aluminium economy is a circular economy. For most aluminium

products, the metal is not actually consumed during the product's lifetime, but

simply used with the potential to be used again through recycling. Aluminium can be

recycled again and again without any loss of its inherent properties, since its atomic

structure is not altered during melting. Therefore, the life cycle of an aluminium

product is not the traditional "cradle-to-grave" sequence, but rather a renewable

"cradle-to-cradle". In all of its activities Avon Metals, and indeed the aluminium

industry per se, aims towards a position of sustainability in environmental and social

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industry per se, aims towards a position of sustainability in environmental and social

terms.

The high value of aluminium scrap is a key incentive and major economic impetus for

recycling, independent of any legislative or political initiatives to encourage

recycling. Aluminium scrap has considerable market value because most of the

energy required for the production of primary aluminium is embodied in the metal

itself and, consequently, in the scrap.

Therefore, the energy needed to melt aluminium scrap is only a fraction of that

required for primary aluminium production. Recycling of aluminium products needs

only 5% of the energy needed for primary aluminium production.

Avon Metals promotes other forms of recycling on site and has segregated collection

points for the following office consumables: -

� Printer & toner cartridges

�Plastic vending cups / bottles

� Redundant mobile / office telephones

� Paper & Cardboard

� Aluminium & steel beverage cans

� Glass bottles

� Electrical & electronic equipment

� Newspaper & magazines

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SDI 10

PROTECTION OF LOCAL WILDLIFE & PROMOTION OF BIODIVERSITY

Gloucestershire Wildlife Trust is the county's leading conservation charity dedicated

to wildlife and Avon Metals is proud to be an active Corporate Sponsor, extending

our commitment to our environment and helping to save some of the last remaining

habitats for wildlife in our County. Partnership is available to companies committed

to reducing their environmental impact. We feel honoured to help play a direct part

in looking after Gloucestershire's natural heritage.

Avon is also a Slimbridge Wildfowl and Wetlands Trust Corporate Partner. With over

60 years experience of wetland conservation, WWT create and restore wetlands to

help reverse the loss of these important areas throughout the world. In the UK,

2,000 hectares of wetland wildlife reserves provide winter refuge for more than

150,000 waterbirds.

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The work Slimbridge carries out compliments Avon Metals’ present and future

business plan to become totally sustainable. Conservation of UK wetlands helps

sustainability in several ways: -

� Wetlands act as a natural “carbon sink” and help to offset our carbon emissions.

� Reed beds naturally detoxify sewage water before it enters local river systems.

� Wetlands help combat flooding – the risk being demonstrated by the 2007

Gloucestershire floods.

� Many other “ecosystem services” and anthropocentric benefits that are often not

readily visible, including: - natural regulation of air quality, pollination and biological

pest control.

Slimbridge is home to an astounding array of wildlife including the world's largest

collection of swans, geese, and ducks amongst others. In 2008 Avon Metals funded a

“dragonfly pond” project at Slimbridge to encourage dragonflies to the site.

Additionally, this will promote other pond wildlife such as frogs, newts and toads.

In 2009 Avon sponsored a schools competition by in conjunction with WWT, Alupro

and Gloucester City Council for all Gloucestershire schools to design and make a

dragonfly sculpture (as an homage to the pond) out of recycled aluminium foil and

drinks cans. This amalgamated several important themes for us – recycling, carbon

reduction, education, nature, art, & biodiversity.

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SDI 11

REDUCTION OF FRESHWATER CONSUMPTION PER TONNE OF ALUMINIUM

PRODUCED & RAINWATER CAPTURE (INCLUDING WATER COP)

As part of our "20/20 Vision" initiative, Avon Metals has made strides to reduce our

water use. We have set ourselves a target to reduce our water use by 5% per annum.

Our policy includes: -

� Carrying out a survey to locate all areas of water use on site

� Identifying areas to reduce water waste.

� Installation of meters to regularly monitor water use

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� Implementing a water saving campaign

� Staff training to ensure awareness of products can be washed down the

drain.

� Checking the integrity of on site containers

� Avoiding leakages and spills

� Fitting of flow restrictors and automatic cut-off devices

Avon Metals has purchased approved water saving devices on the Water Technology

List (WTL), including flow restrictors and automatic shut-off devices.

Avon Metals is registered with the Envirowise Rippleffect - a 3 stage initiative

involving data collection, development and implementation an action plan and

measuring savings.

Data has been collected using the Global Water Tool developed by the World

Business Council of Sustainable Development (WBCSD). In the year July 2007 - June

2008 we reduced our water consumption by 0.02 cubic metres per tonne of finished

product, representing a 4% decrease.

The roofs of our factory buildings make good collectors of rainwater. Avon Metals

intends to capture the runoff rainwater in storage tanks, filter particles through a

mesh and then re-use this water to cool our ingots.

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SDI 11 CONTINUED – WATER COP

THE CEO WATER MANDATE

On July 5th, 2007, the chief executive officers of bottled water giants Coca Cola and

Nestlé joined four other multinational corporations, including water privateers Suez

and Läckeby Water Group, to announce a new “water mandate” within the United

Nations Global Compact.

The CEO Water Mandate is an initiative developed in partnership between the United

Nations Global Compact, the Government of Sweden and a group of committed

companies and specialized organizations dealing with the problems of water scarcity

and sanitation. It is designed as a private-public initiative with a focus on developing

strategies and solutions to contribute positively to the emerging global water crisis. The

CEO Water Mandate seeks to engage a critical mass of companies from around the

world, willing to undertake serious efforts, in partnership with other stakeholders, to

address this challenge. Whenever possible, this initiative will coordinate efforts and

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address this challenge. Whenever possible, this initiative will coordinate efforts and

work with existing water programs -- both global and local -- in order to maximize

impact.

As a signatory to the United Nations Global Compact (UNGC), Avon Metals’ CEO,

Steven Munnoch, has endorsed the CEO Water Mandate. As estimated by the UNGC,

more than 1 billion people do not have access to clean water, while 2.6 billion people

lack access to adequate sanitation. Water scarcity is linked to poor education, poverty,

disease, and increasingly, conflict. Companies have a role to play in advancing water

management.

MISSION STATEMENT

The CEO Water Mandate seeks to make a positive impact with respect to the emerging

global water crisis by mobilizing a critical mass of business leaders to advance water

sustainability solutions – in partnership with the United Nations, civil society

organizations, governments, and other stakeholders.

As a special initiative of the UN Secretary-General, The CEO Water Mandate offers a

unique action platform to share best and emerging practices and to forge multi-

stakeholder partnerships to address the problems of access to water and sanitation.

The CEO Water Mandate covers six areas: Direct Operations; Supply Chain and

Watershed Management; Collective Action; Public Policy; Community Engagement; and

Transparency.

Endorsers of The CEO Water Mandate recognize that through individual and collective

action they can contribute to the vision of the UN Global Compact and the realization of

the Millennium Development Goals.

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SDI 11 CONTINUED – WATER COP

STATEMENT OF CONTINUED SUPPORT FOR THE UN GLOBAL COMPACT’S CEO WATER

MANDATE

Water is essential for sustaining life. However, this valuable resource is distributed

unevenly throughout the world and is also often used wastefully and polluted. This is

resulting in severe ecological damage, disease, food shortages and violent conflicts. By

developing and promoting solutions to support efficient and responsible consumption

of water, Bayer is committed to conserving one of the most crucial of all raw materials.

A commitment to protecting water quality and reducing water consumption has long

been part of Bayer company policy.” Drinking water is a resource in scarce supply. A

mere 2.5 percent of all the water on Earth is freshwater – and most of that is either

contained in ice, or is present as groundwater and therefore difficult to access.

According to estimates by the United Nations, water shortages will assume critical

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According to estimates by the United Nations, water shortages will assume critical

levels in numerous regions over the course of the next few decades. Today, over a

billion people already have no access to clean water. As the world’s population

continues to grow and consumption habits change, the amount of drinking water

needed, and the volume required for sanitary and hygienic purposes and especially for

food production, will continue to increase. Increased urbanization is intensifying the

pressure on local water resources and, particularly in the emerging countries, water

pollution is on the increase. In some areas, climate change will exacerbate the situation

still further due to decreased precipitation and rising sea levels.

Efficient water usage and water pollution control are key issues when it comes to

sustainable development. Agriculture has a crucial role to play in this respect, as the

majority of the water consumed in the world (around 70 percent) is used in the

cultivation of foodstuffs.

As an active UNGC signatory, Avon Metals are also part of the CEO Water Mandate

which focuses on achieving more sustainable consumption of this essential resource. By

joining the CEO Water Mandate, Avon Metals commits to setting meaningful water

reduction targets and tracking and reporting water usage, and has indicated its

commitment to adhere to a comprehensive approach to water management. The

Mandate is broken into six key areas: direct operations; supply chain and watershed

management; collective action; public policy; community engagement; and

transparency. Each key area concludes with a pledge for signers to commit to a number

of related actions.

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SDI 11 CONTINUED - COP

Description of policies and practical actions that Avon Metals have taken to

implement the CEO Water Mandate elements.

Our policies include: -

� Carrying out a survey to locate all areas of water use on site

� Identifying areas to reduce water waste.

� Installation of meters to regularly monitor water use

� Implementing a water saving campaign

� Staff training to ensure they are aware if what products can be washed down the

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� Staff training to ensure they are aware if what products can be washed down the

drain.

� Checking the integrity of on site containers

� Avoiding leakages and spills

� Fitting of flow restrictors and automatic cut-off devices

1. Direct Operations

Avon Metals understands our water use and have integrated robust water

management processes. We have used the GEMI Water Sustainability Tool to build

awareness about the plant’s relationship to water and have purchased approved

water saving devices on the Water Technology List (WTL), including flow restrictors

and automatic shut-off devices.

2. Supply Chain and Watershed Management

Avon Metals does have supplier guidelines but we are not yet working with suppliers

to build capacity and reduce their water footprint. In the future we intend to

encourage our suppliers to improve their water conservation, quality monitoring,

waste-water treatment, and recycling practices by: -Building capacities to analyze

and respond to watershed risk.; Encouraging and facilitating suppliers in conducting

assessments of water usage and impacts.; Sharing water sustainability practices –

established and emerging –with suppliers.; Encourage major suppliers to report

regularly on progress achieved related to goals.

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SDI 11 CONTINUED – WATER COP

3. Collective Action

Avon Metals fosters a partnership approach with a variety of organisations, including

suppliers and local businesses at a regional and local level. In addition, we are

members of, or work in partnership with, a range of organisations, including the

United Nations and GRI.

4. Public Policy

Avon Metals are committed to making a positive contribution on water through our

business activities, and as part of the CEO Water Mandate we are working alongside

members on water-related supply chain issues; collective action; public policy; and

community engagement . We believe that we can play a powerful role in helping to

advance key public policy issues related to our business by using our corporate voice.

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advance key public policy issues related to our business by using our corporate voice.

5. Community Engagement

Avon Metals is a Corporate Partner of Gloucestershire Wildlife Trust and Slimbridge

Wildfowl and Wetlands Trust, promoting bio-diversity in the region. WWT create and

restore wetlands to help reverse the loss of these important areas throughout the

world. In the UK, 2,000 hectares of wetland wildlife reserves provide winter refuge for

more than 150,000 waterbirds. The work Slimbridge carries out compliments Avon

Metals’ present and future business plan to become totally sustainable. Conservation

of UK wetlands helps sustainability in several ways; wetlands act as a natural “carbon

sink” and help to offset our carbon emissions; reed beds naturally detoxify sewage

water before it enters local river systems, wetlands help combat flooding –the risk

being demonstrated by the 2007 Gloucestershire floods; many other “ecosystem

services” and anthropocentric benefits that are often not readily visible, including: -

natural regulation of air quality, pollination and biological pest control. Slimbridge is

home to an astounding array of wildlife including the world's largest collection of

swans, geese, and ducks. Other important wildlife includes kingfisher, flamingos,

water voles, beavers, redshank, brown hares, dragonflies, wild otters, grass snakes

and wild orchids.In2008 Avon Metals funded an environmental ecosystem project at

Slimbridge to encourage dragonflies to the site. Additionally, this will promote other

pond wildlife such as frogs, newts and toads. We plan to follow up on our successful

2007/2008 schools competition by running an event in 2009 in conjunction with

WWT, Alupro and Gloucester City Council for all Gloucestershire schools to design and

make a dragonfly sculpture out of recycled aluminium foil and drinks cans. Slimbridge

have kindly agreed to exhibit the winning entries. This will tie in several important

themes for us –recycling, carbon reduction, education, nature, art, & biodiversity

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SDI 11 CONTINUED – WATER COP

6. Transparency

Avon Metals openly publish our targets, results and activities in accordance with the

GRI (G3) guidelines and report on progress against our commitments such as the CEO

Water Mandate. This information is made public through our Sustainability Report

published on our corporate website www.avonmetals.com, the UN Global Compact

site www. globalcompact.org, and also www.corporateregister.com–a leading CSR

information portal. Avon Metals is also a member of the World Economic Forum’s

Partnership Against Corruption (PACI) initiative, galvanising our commitment to

transparency and fair play.

Measurement of Outcomes

Avon Metals uses the GRI G3 Guidelines to measure qualitative/quantitative

outcomes, or future expected outcomes, related to the CEO Water Mandate

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outcomes, or future expected outcomes, related to the CEO Water Mandate

elements. We spotlight our direct water consumption in “Our 20/20 Vision”

Sustainability Report, and to understand water and other environmental issues in our

supply chain, we conduct annual engagement surveys with key suppliers. Data has

been collected using the Global Water Tool developed by the World Business Council

of Sustainable Development (WBCSD). Outcomes are reported in “Our 20/20 Vision”

Sustainability Report.

GRI G3 guidelines currently reported:

EN8 Total water withdrawal by source

Source of Withdrawn Water2006

2007

2008

2009

2010

Surface water, including water

from wetlands, rivers, lakes, and

oceans

N/A N/A N/A N/A N/A

Ground water N/A N/A N/A N/A N/A

Rainwater collected directly and

stored by the reporting

organisation

N/A N/A N/A N/A N/A

Waste water from another

organizationN/A N/A N/A N/A N/A

Municipal water supplies or other

water utilities3747 4907 4755 4130 5321

TOTAL WATER WITHDRAWAL 3747 4907 4755 4130 5321

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SDI 11 CONTINUED – WATER COP

EN10 Percentage and total volume of water recycled and reused.

The roofs of our factory buildings make good collectors of rainwater. Avon Metals

intends to capture the runoff rainwater in storage tanks, filter particles through a

mesh and then re-use this water to cool our ingots. The roofs of our factory buildings

make good collectors of rainwater. Avon Metals intends to capture the runoff

rainwater in storage tanks, filter particles through a mesh and then re-use this water

to cool our ingots. This initiative has been started and completion is aimed for 2012.

When considering the average rainfall figures published by the Met Office, our runoff

co-efficient and the size of our roof area, we anticipate capturing 250,000 litres per

annum of renewable water.

EN 21 Total water discharge by quality and destination

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EN 21 Total water discharge by quality and destination

Avon Metals is dedicated to implementing innovative ways to conserve water,

including rainwater capture, and identifying by-product synergy opportunities to

reuse the water for beneficial purposes. A large proportion (70%) of the water we

use on site is for cooling down molten metal and this water evaporates into the

atmosphere. The remaining 30% passes through our interceptor tanks to remove any

solid matter or oils before being discharged into the foul sewers. Severn Trent Water

have assessed our site and have confirmed that the water we discharge is 100% safe

to return to the water course and we receive a 90% reduction on our sewage levy as

an incentive to maintain this process.

Water Discharges (estimated)

GRI G3guidelines that we intend to report on in the future:

EN 9 Water sources significantly affected by water

EN 25 Identity, size , protected status, and biodiversity value of water bodies and

related habitats significantly affected by the reporting organisation’s discharges of

water and runoff.

Water exiting Avon Metals’ site 2006

2007

2008

2009

2010

Water evaporated through molten metal

cooling process

2631 3181 3527 2891 3725

Water passing through interceptors and

into foul sewer

1127 1363 1512 1239 1596

Freshwater consumption M³/t of finished

product

0.39 0.48 0.46 0.45 0.44

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HEALTH & SAFETY - REDUCTION IN WORKPLACE INJURIES

The Directors of Avon Metals recognise that Health & Safety is of paramount

importance to us and is taken into account in every management decision we

make and every process we carry out.

Avon Metals has started the process to attain the Occupational Health & Safety

standard OHSAS 18001. This will be in place by 2012 and will integrate seamlessly

with our existing ISO 9001 Quality and ISO 14001 Environmental Management

Systems. An aluminium foundry and non-ferrous scrap yard can be a dangerous

place with many potential hazards – heat, airborne dust contaminants, dust and

fumes from molten metal, vibration, noise, manual handling and plant operation.

Our entire workforce – from senior management to shop floor – has a focus on

fundamental safety systems and are made aware such hazards and of their

responsibility within their own area. We promote good practice on a day-to day

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responsibility within their own area. We promote good practice on a day-to day

basis and have a 3 stage HSE strategy, in line with the Health & Safety At Work

Act 1974: -

1) Identification of hazards & potential risks

2) Take action to prevent & control risks

3) Keep control measures under regular review assessment.

Avon Metals is involved in several industry specific Health & Safety Initiatives

including The Cast Metals Federation SHIFT (Safety & Health Foundry Targets

Initiative), designed to share best practice through quarterly meetings at the

National Metalforming Centre which generally focus on specific areas, such as

Hand/Arm vibration, Manual Handling or Workplace Transport; and through the

Aluminium Federations’ AIMS (Aluminium Industry Made Safer) initiative, whose

target is to achieve a 10% reduction in Lost Time Incident (LTI) rate over a 3 year

period.

We pride ourselves on our “zero fatalities rate” throughout the history of the

company - much lower than our industry norm. Our Lost Time Incident Rates and

Total Recordable Incident Rates are slightly higher than average for our industry.

Our “Target Zero” aim is to reduce this rate in 2011 and beyond.

The rate of RIDDOR reportable accidents amongst SHIFT group members has

reduced from 4,214 / 100,000 employees in 2002 to 1,777 / 100,000 in 2007 - a

58% reduction. In 2010, Avon Metals only had 1 RIDDOR reportable accident.

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HEALTH & SAFETY - REDUCTION IN WORKPLACE INJURIES

The company conducts annual health screenings, including monitoring of hearing

levels, lung function, bi-annual personal air monitoring and night workers

assessment.

An independent H & S consultant visits on a monthly basis to carry out “completely

independent” risk assessment surveys. A written report stating action required is

produced. Listed in this Sustainability Report are some of the daily Health & Safety

issues we face and how we tackle them effectively: -

HEAT

The furnaces and molten metal in a foundry create a hot working environment.

Dehydration, heat cramps, heat exhaustion and heat stroke are some of the health

effects foundry workers can experience from exposure to excessive heat.

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effects foundry workers can experience from exposure to excessive heat.

We combat this by using fans and flues to reduce the air temperature, giving

regular work breaks in cool areas, job sharing and rotation, and using personal

protective equipment such as eye wear, heat reflective clothing, gloves and

footwear

DUST & FUMES

Foundry operations create dusty conditions exposing workers to various health

risks. Foundry workers may be exposed to various types of dust, including

nuisance dust, wood dust, metal dust and airborne RSC (Respirable Crystalline

Silica) dust. Specific illnesses have been linked with exposure to certain types of

dust. Fumes generated from melting of molten metal may irritate the lungs.

We deal with dust and fumes in various ways – extraction canopy hoods over the

furnaces, DISA Airmaster state-of-the-art dust extraction plant, training in safe

work practices and use and maintenance of personal protective equipment (PPE)

and respiratory protective equipment (RPE), respirators with organic vapour

filters for organic vapours. When relining furnaces, operatives use air fed RPE

with an assigned protection factor (APF) of minimum 40 and we use a permit-to-

work system for access. When cleaning up metal dust we use a type H vacuum

cleaner fitted with a HEPA filter, instead of a brush. Dross is sent for reprocessing

almost as quickly as it is generated, reducing the chance of it getting wet and

emitting gases. We ensure that workers shower and change after every work

session and use a contract laundry company to wash work clothing.

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MOLTEN METAL

Serious burns may result from splashes of

molten metal and radiant heat at any time in the

melting and pouring areas. Sparks from molten

metal may also damage the eyes. Exposure to

infrared and ultraviolet radiation may result in

eye damage including cataracts. There are many

practices which may increase the risk of hot

metal splashes: charging a furnace with

contaminated or moist scrap metal and alloys;

using moist tools, moulds or other material

when contacting molten metal.

Our control methods for molten metal include: -

maintaining a safe working distance, ensuring

that all raw material ladles and other equipment

that may come in contact with molten metal

must are completely dry; restricting

unauthorised access to the furnace area by

barriers and signage, restricting visitors and

workers from wearing synthetic clothing,

including undergarments when entering the

furnace and pouring areas; keeping the melting

and pouring areas free of combustible material

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and pouring areas free of combustible material

and volatile liquids; provide training in safe work

practices and the use and maintenance of

personal protective equipment including full

faceguards. Fire extinguishers of all types are

close to hand throughout the facility.

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HAND ARM VIBRATION (HAV)

Although a very low risk, at times our foundry workers may be exposed to whole-

body vibration and hand-arm vibration from hammering ingots and cleaning

furnaces with pneumatic drills. The health effects of vibration can include blood

pressure and heart problems, nervous disorders, and blanching and numbness in the

fingers.

Our control measures for vibration include: using tools with vibration dampers,

monitoring and limiting the use of vibrating equipment, providing protective gloves.

NOISE

Avon employees are subjected to a variety of noise sources, such as induction

furnaces, casting track hammers; fettling and scrap handling are capable of causing

damage to hearing.

Where high levels of noise are present, workers wear personal hearing protectors.

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HEALTH & SAFETY - REDUCTION IN WORKPLACE INJURIES

To control noise we have installed a new improved ingot mould design to aid

ingot discharge and minimise the need for fettling on most of our casting tracks

that has drastically reduced the amount of excess metal to be removed after

casting. This in turn removes or reduces the need for fettling.

PLANT & MACHINERY

Avon Metals uses a wide range of metal processing equipment Including fork lift

trucks, balers, shears, croppers, and furnaces. Burns, cuts and lacerations and

amputations are some of the injuries that can result from poor maintenance,

repair and guarding and use of such plant and machinery.

We deal with such risks by: - enclosing or guarding dangerous machines;

neutralising potential energy sources during maintenance and repairs, full

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neutralising potential energy sources during maintenance and repairs, full

operator training and provision of personal protective equipment.

Visitors and workers with medical implants, joints, plates or similar objects are

kept away from our induction furnaces as the magnetic fields involved in the

melting process can induce a charge in the metallic implant. Personnel with

cardiac pace makers are particularly at risk and are restricted from approaching

the induction equipment.

COSHH

All laboratory substances (including acids) and paints for identifying finished

product are controlled under COSHH (Control of Substances Hazardous to Health)

regulations and are kept in secure, fire-proof cabinets.

MANUAL HANDLING

Workers in most areas within Avon are required to perform manual tasks including

lifting, driving vehicles, tool use, drossing off, ingot stacking, which could lead to

musculoskeletal or repetitive strain disorders.

We have reduced manual handling risks by redesigning equipment or work practices.

A good example of this is ingot stacking. We have invested in spring loaded tables

which maintain a constant, comfortable working height for the operative, thus

avoiding the need to bend over all the time and strain the back. Wherever possible,

lifting is mechanically assisted through the use of forklifts, grabs and hoists. .

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SDI 12 CONTINUED….

HEALTH & SAFETY - REDUCTION IN WORKPLACE INJURIES

WORKPLACE TRANSPORT

Every year in UK industry people are killed or seriously injured

in workplace transport related accidents. Commonly accidents involve people being hit

or run over by vehicles such as forklift trucks, cars, lorries, vans etc.

At Avon Metals, we control the risk of this happening by ensuring that: -

i) the design and layout of the workplace enables us to separate vehicles and

pedestrians as much as possible;

ii) loading and unloading operations are carried out in areas away from passing traffic

and pedestrians;

Iii) our vehicles are fitted with horns, lights, reflectors, reversing lights;

iv) suitable designated parking areas are provided for work related vehicles (both

permanent and visiting);

v) there are safe systems of work for activities such as coupling/uncoupling trailers,

covering and uncovering vehicle loads and accessing the top of vehicles;

vi) we provide traffic control features such as clearly marked pedestrian crossing

points, mirrors at blind corners, and pedestrian barriers (especially at exits onto traffic

routes)

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vii) provision of high visibility vests for staff and visitors – be seen, be safe.

SLIP TRIPS

We promote good housekeeping to ensure that loose lumpy or granular metals are

kept in proper storage and that any spills of metal or liquids are cleaned up quickly.

Skin creams are available to help prevent dermatitis.

FIRST AID

Several Avon managers and foreman are fully trained First Aiders and first aid kits are

readily available throughout our factory and office complexes.

LTI Number of Lost Time Incidents TRI Number of Recordable Incidents

RATE = Number of Employee Hrs Worked RATE = Number of Employee Hrs Worked

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 2 7

Avon Metals

Health & Safety

Statistics

2005 2006 2007 2008 2009 2010 Aluminium

Industry

Average

Lost Time Incident

(LTI) Rate

4.8 5.6 6.5 14.65 4.96 13.84 5.6

Total Recordable

Incident (TRI) Rate

15.5 10.31 20.8 29.3 27.3 16.92 12.1

Fatalities 0 0 0 0 0 0 3

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SDI 13

STAFF TRAINING AND PERSONAL DEVELOPMENT

Avon Metals believes that our people are our most valuable asset and encourages a

healthy work-life balance that ensures that the workplace is clean, safe and healthy at

all times.. The company operates a no smoking policy. Our staff turnover was affected

by unfortunate, but necessary redundancies in 2009 due to the decline in the global

economic climate, but since then we have returned to pre-credit crunch staffing levels

and our productivity has increased,

The Company provides staff with a generous remuneration and incentives programme

including death in service benefit, generous annual leave per year, flexible retirement

plans and help towards achieving work-related qualifications. When two long serving

employees suffered from long-term illness, we were delighted to help them meet

their ongoing living costs.

The Company operates an employee development review process, which provides an

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The Company operates an employee development review process, which provides an

opportunity for all team members to work with their line manager to plan their

development for the coming year. This may include formal training, gaining

experience in new areas, and/or mentoring. This allows us to identify and create

relevant career pathways for our workforce. Wherever possible we endeavour to

“promote from within”.

Our training courses for employees include: - Effective Leader Management; Forklift /

heavy plant operation; Health & Safety; First Aid at Work; Business Improvement

Techniques; Technical courses; REACH (Registration, Evaluation and Assessment of

Chemicals) Avon utilises the skills and assets of a multinational workforce. Avon

Metals current language resources include Chinese Mandarin and Polish as a mother

tongue and many European languages as a secondary asset. The Company organises

regular scheduled ESOL (English for Speakers of Other Languages) for the foreign

workers it employs.

Performance reviews are also conducted annually, creating the opportunity to identify

specific objectives for each team member, to review progress against previous

objectives. It is the policy of the Company that the training, career development and

promotion of disabled persons should, as far possible, be identical with that of other

employees.

Staff are encouraged to develop their skills, and these will be furthered and honed

under our impending Investors In People (IIP) implementation.

Wage levels are above average for the industry, and financial incentives are in place

for production levels , skill level & night shift work. We also introduced Environmental

and Health & Safety related bonuses in 2009-2010.

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SDI 13

STAFF TRAINING AND PERSONAL DEVELOPMENT

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AVON METALS TRAINING DAYS

Subject Department Attendees Days Total

MAS Lean Mfg Foundry 6 8 48

OHS All departments 55 1 55

HR Administration 2 6 12

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First Aid Foundry 6 3 18

Aluminium Applications Administration 2 1 2

BERR Export Docs Administration 1 1 1

Health & Safety Foundry 2 3 6

Totals 142

Total Employees 57

Days per Employee 2.49

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SDI 13

STAFF TRAINING AND PERSONAL DEVELOPMENT

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Y/E 31.7.09 Y/E 31.7.10

Total Number of Avon Employees 38 57

Percentage of Full-Time Employees 100 % 100 %

Percentage of Part-Time Employees NIL NIL

Percentage of Permanent Staff 100 % 100 %

Percentage of Temporary Staff NIL NIL

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 3 0

Percentage of Staff Employed in Gloucester 100 % 100 %

Percentage of Male Employees 93 % 93 %

Percentage of Female Employees 7 % 7 %

Percentage of Minority Employees 40 % 49 %

Percentage of Non-Minority Employees 60 % 51 %

Percentage of Employees aged below 30 28 % 31 %

Percentage of Employees aged 30 to 50 34 % 42 %

Percentage of Employees aged over 50 38% 27 %

Average Male Base Salary Per Annum £21,735 £22,000

Average Female Base Salary Per Annum £17,850 £19,000

Ratio of Male to Female Average Base Salary 1.22 : 1 1.16 : 1

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SDI 14

IMPROVEMENT & DEVELOPMENT OF COMMUNITY RELATIONS

In both 2007 & 2009 Avon Metals, in conjunction with Alupro and Gloucestershire

County Council, co-ordinated 2 competitions for Gloucestershire schools.

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In 2007 over 40 participating schools had to

design and build a tree sculpture using

recycled aluminium foil and drinks cans. The

winning entries received top-of the-range

camcorders, and the overall winning tree is

proudly displayed in our reception area.

Runners up prizes included £100 for second

place and £50 for third place. All of the

schools who took part in the competition

received a native fruit tree of their choice, to

plant in their school grounds.

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This idea of tree planting is further echoed through our corporate support and

membership fees to Alupro. Alupro's Tree Campaign focuses on tackling

deforestation in Africa whilst at the same time providing the means and know-how

to develop small businesses in rural communities in Malawi. A tree will be grown for

every tonne of aluminium cans and foil recycled in the UK. The fruit tree, will provide

good food as well as the basis for fruit drying and juicing enterprises, adding value to

the crop as the trees mature and promoting biodiversity in the region.

In November 2007, Avon Metals won the Book Check Cup for outstanding work in

the region at the Gloucestershire Ambassadors Millennium Dinner and

Gloucestershire First were involved in the judging of our tree competition for

Gloucestershire schools. In 2010, the Directors of Avon were invited by Slimbridge

Trust to Buckingham Palace to meet the Duke of Edinburgh, following our

collaboration with them on various environmental projects.

Avon Metals have a good relationship with the local Police force and we work closely

with them in an attempt to eradicate local crime particularly thefts of valuable

metals both from other local companies and at our own facility. The funds generated

by such crime is often used to fund drug habits.

Avon supports our staff in their endeavours and activities outside the workplace and

has sponsored the football team of one of our employees – Tuffley Rovers. The

Company has also made financial contributions to a successful Gloucester school

rugby team, with many players filtering into Gloucester Rugby Club and England

Juniors.

plant in their school grounds.2007 Winning Entry

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SDI 14

IMPROVEMENT & DEVELOPMENT OF

COMMUNITY RELATIONS CONTINUED......

“WASTE TO WILDLIFE” COMPETITION 2009

In 2009, the competition "From Waste to Wildlife" was jointly organised by

Gloucestershire County Council's Waste Unit and WWT Slimbridge, supported by The

Aluminum Packaging Recycling Organisation (Alupro) and the British Dragonfly

Society. The competition and the creation of the new dragonfly pond at Slimbridge

was sponsored by Avon Metals Ltd Gloucester, who donated a £400 first prize.

The official launch of the competition took place on Tuesday 24 February at the

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The official launch of the competition took place on Tuesday 24 February at the

Slimbridge Wetland Centre and pupils from Slimbridge Primary School took part in

workshops on recycling and the lifecycle of dragonflies.

Veronica Morriss, centre manager at WWT Slimbridge, said: "This is a fantastic

opportunity for Slimbridge to work with Avon Metals and Gloucestershire County

Council to promote both wildlife and recycling in a fun and creative competition. This

is an imaginative competition and one in which we can celebrate both the numerous

species of dragonfly we have here and our new dragonfly pond, kindly funded by

Avon Metals. We look forward to seeing some inspired creations from our local

schools and are honoured to be hosting what will be a wonderful exhibition.“

Hannah Gray, Waste Education Officer for Gloucestershire County Council said: "I

think the competition will capture children's imagination, and I am looking forward

to seeing the end results. I also believe that youngsters will learn about the

importance of the 3Rs- Reduce, Reuse and Recycle. This competition should help

them make the link between protecting our environment and throwing away less

materials.

.All 350 schools in Gloucestershire

were invited to create a sculpture of

a dragonfly (or swarm of

dragonflies) made out of aluminum

foil and many entries were

suspended from the ceiling in

Slimbridge visitors centre in a

magical aerial display

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SDI 14

IMPROVEMENT & DEVELOPMENT OF COMMUNITY RELATIONS CONTINUED....

Second Life Metals

In 2010 Avon Metals will partner with the Association of Private Cemeteries &

Crematoria (APPC) to recover metals from privately owned crematoria in the UK.

New Government legislation means that metals left over from the cremation

process are not allowed to be buried in the ground .

Avon was approached by APCC in 2009 to see if we could assist. Metals recycled

will include Cobalt Chrome alloys, Titanium (orthopedic joints) & Steel (coffin nails).

Avon will provide this sensitive service to private crematoria throughout the UK,

and the money that is generated from the recovery of these valuable metals will be

used to fund bereavement charities nominated by APCC.

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used to fund bereavement charities nominated by APCC.

It is a poignant thought to know that metals that would otherwise have gone to

landfill can now find a second life and be respectfully recycled in to new products,

saving the environment and helping provide a new income stream to support

worthwhile charities.

www.apcandc.co.uk

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SDI 15

UNITED NATIONS GLOBAL COMPACT SIGNATORY

Avon Metals is a participant in the United Nations Global Compact. Launched by Kofi

Annan in 1999, the Global Compact initiative is a network of UN agencies,

corporations, NGOs, labour, and academic institutions that endorse a set of

principles on human rights (derived from the Universal Declaration of Human

Rights), labour, the environment and anti-corruption.

THE 10 PRINCIPLES OF THE GLOBAL COMPACT

HUMAN RIGHTS

PRINCIPLE 1: Businesses should support and respect the protection of

internationally proclaimed human rights; and

PRINCIPLE 2: make sure that they are not complicit in human rights abuses.

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LABOUR STANDARDS

PRINCIPLE 3: Businesses should uphold the freedom of association and the effective

recognition of the right to collective bargaining;

PRINCIPLE 4: the elimination of all forms of forced and compulsory labour;

PRINCIPLE 5: the effective abolition of child labour; and

PRINCIPLE 6: the elimination of discrimination in respect of employment and

occupation.

ENVIRONMENT

PRINCIPLE 7: Businesses should support a precautionary approach to environmental

challenges;

PRINCIPLE 8: undertake initiatives to promote greater environmental responsibility;

and

PRINCIPLE 9: encourage the development and diffusion of environmentally friendly

technologies.

ANTI-CORRUPTION

PRINCIPLE 10: Businesses should work against corruption in all its forms, including

extortion and bribery.

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SDI 15

UNITED NATIONS GLOBAL COMPACT SIGNATORY

STATEMENT OF CONTINUING SUPPORT FOR THE UN GLOBAL COMPACT

Avon Metals has been a signatory to the United Nations Global Compact since 2007,

and we continue to align our operations and strategies with its ten principles in the

four key areas of Human Rights, Labour Environment and Anti-corruption.

Signing the Global Compact affirms our long-standing commitment to strive to

conduct business responsibly, and where possible, we actively encourage our

business partners and other key stakeholders to join the initiative.

Our Communication on Progress (COP) is made available to stakeholders through the

UN Global Compact website (www.unglobalcompact.org) and our own corporate

internet site (www.avonmetals.com).

Ban Ki Moon, Un Secretary General

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internet site (www.avonmetals.com).

In 2008/2009 – 10th December 2008 CEO Statement 60th Anniversary of the

Universal Declaration of Human Rights, CEO Water Mandate, Caring for Climate, Seal

the Deal.

MEASURES AND PRACTICLE ACTIONS

PRINCIPLES 1 & 2

�Avon Metals works with suppliers who share our commitment to human rights.

�Avon Metals Supplier Code of Conduct, required of all third party suppliers,

encourages engagement with key human rights issues such as child labour,

discrimination and working conductions throughout the Supply Chain.

�OHSAS 18001 Standard & Investors In People Standards are in progress

PRINCIPLES 3,4,5 & 6

�All employees made aware of our zero tolerance stance

towards discrimination of any kind.

�Developed Employee Code of Conduct Manual

�English lessons provided for speakers of other languages

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PRINCIPLES 7,8 & 9

�Avon Metals certified to ISO 14001 Standard

�Corporate sponsor of 2 wildlife organisations

�Reduction of carbon dioxide and other Greenhouse Gas emissions

�Reduction in water consumption

SDI 15

UNITED NATIONS GLOBAL COMPACT SIGNATORY

STATEMENT OF CONTINUING SUPPORT FOR THE UN GLOBAL COMPACT

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 3 6

�Set 2020 target to become Carbon Neutral

PRINCIPLES 10

�Anti-Corruption Policy developed and rolled out within the company

�Member of the World Economic Forum’s partnership Against Corruption

Initiative

FUTURE PLANS

�Engage in Global Compact Local Network events

�Attain OHSAS 18001 & Investors In People standards

�In contracts with Chinese suppliers, Avon metals will make reference to

our membership of the Un Global Compact and we will analyse our

suppliers policies on human rights and labour issues.

� Compliance with new UK Bribery Act

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UNITED NATIONS GLOBAL COMPACT SIGNATORY

STATEMENT OF CONTINUING SUPPORT FOR THE UN GLOBAL COMPACT

↓ UN Advert posted in the Financial Times December 10th 2008 showing Avon

Managing Director, Steven Munnoch, as a signatory.

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CARING FOR CLIMATE

“Caring for Climate" is a voluntary and complementary action platform for UN Global

Compact participants who seek to demonstrate leadership on the issue of climate

change. CEOs who support the statement are prepared to set goals, develop and

expand strategies and practices, and to publicly disclose emissions as part of their

existing disclosure commitment within the UN Global Compact framework, that is,

the Communication on Progress.

Caring for Climate is a unique initiative – a commitment to action by business and a

call to governments, incorporating transparency. It offers an interface for business

and governments at the global level, with the potential of rapidly becoming the

leading platform for pragmatic business solutions -- transcending national interests

and responding to the global nature of the issue at stake. Moreover, the broad

geographical spread of its supporters, involving both leading actors from developed

and emerging economies, reinforces the novel nature of this engagement platform

SDI 15 CONTINUED...

STATEMENT OF CONTINUING SUPPORT FOR THE UN GLOBAL COMPACT

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and emerging economies, reinforces the novel nature of this engagement platform

SEAL THE DEAL

Seal the Deal! was a UN campaign calling for a fair, balanced and effective post-

Kyoto climate agreement at the UN Climate Change Conference (COP 15), held from

7-18 December 2009 in Copenhagen. In support of Seal the Deal!, The Global

Compact is reached out to its participants to galvanize global business support for

the campaign.

Avon Metals was proud to endorse “Seal the Deal” with the following CEO

statement: -

"Climate Change is of paramount importance to Avon Metals. Changes in the climate

over recent years, and those predicted over the next 100 years, are considered to be

largely a result of modern human life, rather than Mother Nature following her

course. The impacts of Climate Change will affect every living organism on the

planet. To this end, we applaud the United Nation’s Seal the Deal! Campaign calling

for a fair, balanced and effective post-Kyoto climate agreement. As a recycling

company, Avon Metals’ mission is to become a totally sustainable company and our

raison d'être to help preserve our precious environment for future generations. We

are constantly pushing the envelope and challenging ourselves to investigate new

technologies and renewable energy sources to reduce our greenhouse gas emissions

and neutralise our carbon footprint. We look forward to standing shoulder to

shoulder with the UN and tackling Climate Change head on together."

Steven Munnoch, Managing Director, Avon Metals Ltd.

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SDI 16

HUMAN RIGHTS (INCLUDING DEVELOPING AN ANTI-BRIBERY AND ANTI

CORRUPTION INITIATIVE)

HUMAN RIGHTS STATEMENT

“Avon Metals prides itself on its reputation as a fair and ethically run business.

We aim to earn the trust and respect of the businesses and people within our

sphere of influence (see diagram), through our core values of transparency,

accountability, integrity, solidarity, courage, justice & democracy.”

Our Human Rights Policy and Human Rights Statement reflect internationally

recognised principles - including the United Nations Global Compact and the

Universal Declaration of Human Rights and the International Labor Organization's

Declaration on Fundamental Principles and Rights at Work - to promote and protect

human rights in the workplace. We abhor human right abuses and child labour and

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human rights in the workplace. We abhor human right abuses and child labour and

have a “zero tolerance” attitude to these issues.

OUR CORE VALUES

• Transparency

• Accountability

• Integrity

• Solidarity

• Courage

• Justice

• Democracy

EMPLOYEES

We treat our employees with fairness, respect and dignity. We adhere to all

applicable domestic & international laws, include prohibiting child labour, forced

labour, and discriminatory behavior (racial, age, gender, religion or other) as well as

recognising and acknowledging the rights to freedom of association and collective

bargaining. We prefer business partners that treat their employees similarly.

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SDI 16 CONTINUED.....

HUMAN RIGHTS (INCLUDING DEVELOPING AN ANTI-BRIBERY AND ANTI

CORRUPTION INITIATIVE)

SUPPLIERS

We endeavour to conduct our daily business in an ethical and responsible manner

and select and engage business partners who share our good Corporate Social

Responsibility values. We have developed an Anti-Bribery and Corruption policy in

line with principles laid down by the World Economic Forum’s Partnering Against

Corruption Initiative.

Any company wishing to engage with Metals must satisfy the following human rights

selection criteria: -

1) It does not employ engage or otherwise use any child labour in circumstances

such that the tasks performed by any such child labour could reasonably be foreseen

to cause either physical or emotional impairment to the development of such child;

2) It does not use forced labour in any form (prison, indentured, bonded or

otherwise) and its employees are not required to lodge papers or deposits on

starting work;

3) It provides a safe and healthy workplace, presenting no immediate hazards to its

employees. Any housing provided by the Supplier to its employees is safe for

habitation. The Supplier provides access to clean water, food, and emergency

healthcare to its employees in the event of accidents or incidents at the Supplier's

workplace;

4) It does not discriminate against any employees on any ground (including race,

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4) It does not discriminate against any employees on any ground (including race,

religion, disability or gender).

it does not engage in or support the use of corporal punishment, mental, physical,

sexual or verbal abuse and does not use cruel or abusive disciplinary practices in the

workplace;

5) It pays each employee at least the minimum wage, or a fair representation of the

prevailing industry wage, (whichever is the higher) and provides each employee with

all legally mandated benefits;

6) It complies with the laws on working hours and employment rights in the

countries in which it operates;

7) It is respectful of its employees right to join and form independent trade unions

and freedom of association.

8) It is responsible for controlling its own supply chain and that it shall encourage

compliance with ethical standards and human rights by any subsequent supplier of

goods and services that are used by Supplier when performing its obligations to Avon

Metals.

LOCAL COMMUNITY

We consult actively with a diverse range of knowledgeable stakeholders to build

upon our understanding of the human rights issues present in our operating

environments.

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HUMAN RIGHTS (INCLUDING DEVELOPING AN ANTI-BRIBERY AND ANTI

CORRUPTION INITIATIVE)

AVON METALS ANTI-BRIBERY POLICY STATEMENT

“The company has a no tolerance policy towards bribery and corruption. This policy extends

to all the company’s business dealings and transactions in all countries in which it or its

subsidiaries and associates operate. This policy is given force in a detailed anti-bribery

Programme which is constantly revised to capture changes in law, reputational demands and

changes in the business. All employees are required to comply with this policy.”

In an effort to combat global corruption, the World Economic Forum Partnering Against

Corruption Initiative (PACI) was formally launched by CEOs from the Engineering &

Construction, Energy and Metals and Mining industries in January 2004. The PACI brings

together companies in multiple industries from all over the world, regardless of the size of

their company. By signing the PACI Principles, signatory companies like Avon Metals commit

to having a zero tolerance policy towards bribery and to developing and implementing an

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to having a zero tolerance policy towards bribery and to developing and implementing an

anti-corruption programme to guide the behaviour of our employees. The PACI's mission is

to develop multi-industry principles a and practices that will result in a competitive level

playing field, based on integrity, fairness and ethical conduct.

Avon Metals has developed its Anti-Bribery Programme

in conjunction with PACI, the International Business

Leaders Forum, and a 6-step implementation plan laid

down by Transparency International – see page 42.

July 2011 sees the introduction of the new UK Bribery Act. To ensure we have adequate

anti-bribery polices and procedures in place, Avon Metals has incorporated the following six

principles laid down by the Ministry of Justice: -

�Proportionality: "The action you take should be proportionate to the risks you face and to

the size of your business."

�Top level commitment: "Those at the top of an organisation are in the best position to

ensure their organisation conducts business without bribery."

�Risk assessment: "Think about the bribery risks you might face."

�Due diligence: "Knowing exactly who you are dealing with can help to protect your

organisation from taking on people who might be less than trustworthy."

�Communication: "Communicating your policies and procedures to staff and to others who

will perform services for you enhances awareness and helps to deter bribery by making clear

the basis on which your organisation does business."

�Monitoring and review: "The risks you face and the effectiveness of your procedures may

change over time."

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HUMAN RIGHTS (INCLUDING DEVELOPING AN ANTI-BRIBERY AND ANTI

CORRUPTION INITIATIVE)

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SDI 17

PRODUCT STEWARDSHIP(INCLUDING PRODUCT LIFE-CYCLE ASSESSMENT)

Avon Metals plays a vital role in developing and providing beneficial products,

combating environmental degradation, conserving natural resources and ensuring

safe workplaces.

Sustainable recycling is the company's raison d'être and our alloy products are

used in a wide array of aluminium products in the automotive, architectural,

packaging sectors. Aluminium offers lightweight solutions to design problems,

allowing for products that use less raw material and energy.

In 2007 Avon won The Cast Metals Industry Awards supplier of the year awards.

The Award is made for the foundry that has taken both itself and the castings

industry forward during the past 12 months, through a combination of innovation,

expansion, new technology & investment.

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Some tangible examples of using our products are: -

PACKAGING

Lightweight drinks cans require about half the amount of fuel for transportation

compared with returnable glass bottles.

Avon Metals has designed and manufactured an aluminium pallet as an eco-

friendly substitute for conventional timber pallets. Aluminium alloys in the form of

ingots are stacked on the pallets making for a totally recyclable & sustainable

packaging form - the pallet can either be re-used time and again, or if required it

can become sacrificial as its composition is exactly the same as the customers bulk

raw material feed. Recycling aluminum requires only 5% of the energy it takes to

make new aluminum – and produces only 5% of the CO2 emissions. This route

saves a massive 90% in energy costs, creating a huge positive knock on effect to

the environment. Since invention, Avon has supplied over 6000 of its aluminium

pallets into the industry. Their wooden counterparts would have required

valuable natural raw materials and the appropriate disposal through landfill or

incineration.

Avon recycles hundreds of tonnes of aluminium foil scrap every year that would

otherwise end up in landfill.

Product Life Cycle analysis has shown that as much as 90% of the aluminium we

have ever recycled is still in existence in some useful form..

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SDI 17 CONTINUED….

PRODUCT STEWARDSHIP (INCLUDING PRODUCT LIFE-CYCLE ASSESSMENT)

TRANSPORT

The reduction in weight of a medium size car by 100 kgs through substituting steel

with aluminium parts that contain Avon alloys would result in a saving of 900 litres

of petrol during the vehicle’s lifespan. This would also reduce emission of carbon

dioxide by approximately 2 tonnes. There is also immense potential for replacing

steel with aluminium in trains.

BUILDING

Aluminium building products, such as window frames and cladding, have good

insulation properties and conserve heating energy. A large amount of waste

building materials go to landfill, whereas Avon again recycles hundreds of tonnes

per annum back into new products.

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Avon Metals production of aluminium master alloys that use these elements

therefore contributes to the sustainable use of silicon, copper, iron, magnesium,

manganese, zinc and other elements. This effectively means that, at today’s

recycling rate of 4 million tonnes, 200,000 tonnes of alloying elements are

simultaneously conserved by the aluminium industry in Europe every year.

MINOR METALS

Many of the minor metals that Avon trades in have applications that benefit the

environment. Two good examples being 1) Rhenium – used at 3-6% in aircraft

alloys in turbine engines to assist in leaner burning of fuel. Without Rhenium

aircraft such as the Airbus A380 and Boeing Dreamliner would simply not be

possible; 2) Silicon metal used in new photovoltaic and solar applications to

develop sustainable greener energy resources.

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SDI 17 CONTINUED….

PRODUCT STEWARDSHIP (INCLUDING PRODUCT LIFE-CYCLE ASSESSMENT)

LIFE CYCLE ASSESSMENT

A Life Cycle Assessment (LCA) is a comprehensive scientific examination of both the

positive and the negative environmental, social and economic effects of a product

at every stage of its existence, from production to disposal, and beyond. It looks at

the impacts of the 'product system', including: the mining/extraction of raw

materials; fabrication; transportation; use; recycling/ disposal; energy and ancillary

material supplies.

LCA of aluminium products may need to consider the production processes of

bauxite mining (the first stage in aluminium production); production of alumina

(where aluminium oxide is refined from bauxite) and the production of primary

aluminium (using electrolysis).

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Other steps in the aluminium product life cycle include: several semi-fabrication

processes for the production of rolled products, extrusions, wire, tubes, forgings

and castings; and concludes with the end-of-life operations (including the recycling

of scrap materials and final treatment and disposal of waste and by-products).

Designing aluminium products with efficient production and recycling in mind helps

to reduce their impact throughout their life cycle. LCA is used by the aluminium

industry to assess and stimulate environmental improvement in production

processes and product development, and this in turn can also lead to

improvements in the production processes themselves.

For recyclable products such as aluminum, a “cradle-to-cradle” life cycle can be

modeled, where recycled material can substitute primary material. Only the

material that is lost at the various stages of the life cycle needs to be replaced by

primary material as per the illustration.

The use of recycled aluminium further decreases energy consumption and

greenhouse gas emissions, when compared to primary aluminium production. This

adds further value to the basic reductions already achieved by using aluminium per

se - such as in transportation applications.

A typical LCA consists of four main phases: - goal and scope; life cycle inventory;

life cycle impact assessment; and interpretation of results and recommendations.

the community at large.

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SDI 17 CONTINUED….

PRODUCT STEWARDSHIP (INCLUDING PRODUCT LIFE-CYCLE ASSESSMENT)

Avon Metals uses its diligent approach to Product Stewardship to address and

analyse all these activities with regard to risks, opportunities, and value creation in

order to give a holistic overarching view and to find the best overall solutions. The

process involves engaging internal decision-makers from R&D, production,

marketing, or management, as well as external stakeholders such as suppliers,

retailers, customers, consumers, and the general public.

Life cycle product stewardship encompasses a range of issues including best

materials and process selection, safe consumer use of our products (Material Safety

Data Sheets & REACH) and planning for the recovery or safe disposal of materials.

LCA enables Avon to implement positive sustainability initiatives that can bring

about real tangible benefits from its products, such as the design and production of

our unique “Alipallet” that replaces its wooden alternatives. These Avon initiatives

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our unique “Alipallet” that replaces its wooden alternatives. These Avon initiatives

contribute to our long-term profitability, protection and enhancement of the

natural environment, and well-being of the community at large.

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FINANCIAL CONTRIBUTION TO THE LOCAL ECONOMY

Thousands of pounds worth of scrap metal is bought and recycled on a weekly basis

from a wide array of local suppliers including plumbers, fabrication shops, small

metal merchants etc.

We estimate that each year our door-trade ploughs £3 million pounds back into the

Gloucestershire economy.

Our door-trade operations are regulated and audited by the Local Council under

our Permit to Operate, and have a separate accounting schedule designated to

business generated within the local community, and reflects our contribution to

the local economy.

Wherever possible Avon Metals endeavours to support the local economy and

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Wherever possible Avon Metals endeavours to support the local economy and

employ the services of Gloucestershire based companies including haulage

contractors, IT specialists, plant maintenance engineers & printers amongst others.

Avon Metals is a Corporate Partner of Gloucestershire Wildlife Trust and Slimbridge

Wildfowl and Wetlands Trust , promoting bio-diversity in the region.

In addition to sponsoring Gloucester Rugby team at corporate events, the

Company has made financial contributions to St. Peter’s School Rugby Club and

Tuffley Rovers Football Club.

In the past 5 years, St Peter's has supplied numerous players to the Gloucester

Rugby Club Academy, from which Marcel Garvey and Adam Eustace have gone on

to be part of a regular Gloucester first team.

The company is a member of the Gloucestershire First Ambassadors programme

and promotes the county at every available opportunity.

AVON INPUT INTO

GLOUCESTERSHIRE ECONOMY

2006 2007 2008 2009 2010

£ 000’s 1890 2987 2761 1000 1647

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SDI 19

RESEARCH AND DEVELOPMENT

Through our research and development activities, we are continuing to develop products

which provide social and environmental benefits to our customers and society as a

whole. A recent survey conducted by the Carbon Trust highlighted areas of

improvements to reduce our Carbon Footprint and the Company has implemented many

of the recommendations made (see table below).

Capital expenditure projects require full ROI (Return on Investment) analysis and

associated positive and negative impacts on the environment. The Company is also an

active member of the Climate Change Levy scheme operated by the DTI. Avon Metals

works closely with academic groups to develop new innovative aluminium alloys. Several

technical papers have been produced and published in major trade related journals and

have been meet with global critical acclaim.

The company has recently made improvements to the burner systems on its furnaces to

ensure maximum yield recovery from raw material and improve fuel consumption.

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Improvements made as a result

of the Carbon Trust survey.

Rationale Co2

savings

(Tonnes

per

annum)

Energy

savings

(kWh per

annum)

Cost

Savings

(£ per

annum)

Constructed an action plan

Formed an Energy Committee

Conducted Regular Reviews

Improved Staff Awareness

Began an active poster

campaign

Potential energy savings at the site were highlighted through the creation

of a formal framework, increased awareness and improved the monitoring

of the areas and levels of energy consumption.

234.3 806,370 £22,120

Began a lighting management

awareness campaign

There were many instances when lights were being left on in offices and

factory when no personnel were present. Switching of lights when not in

use has helped reduce our power consumption.

3.0 6,928 £424

Repaired compressed air leeks

around the site

Power from compressed air costs around 10 times the cost of the

electricity from which it was made. Leaks found were tagged and repaired

as part of our maintenance schedule.

15.2 35,476 £2,,170

Fitted Passive Infra Red (PIR)

controllers to turn lighting off

when no personnel are present

Lighting office areas where there is sufficient daylight or when personnel

are not present is wasteful. Fitting a controller that only allows light when

personnel are present and daylight is insufficient has minimised our

lighting costs.

1.7 3,905 £239

Replaced halogen floodlights

with HP SON lamps in the ingots

store

Incandescent filament lamps such as halogen floodlights are much less

energy efficient for a given light output than sodium vapour discharge

lamps.

3.8 8,938 £500

Investigated turning off casting

tracks when not in use

Eliminating wasteful operations is a worthwhile saving 14.3 46,175 £1,847

Fitted Variable Speed Drives to

main extractor fan motors

Variable speed drives allow motors to operate at less than full speed and

save energy. If a motor can operate at a 10% reduction, then savings of

25% can be made.

51.5 119,700 £7,326

TOTAL SAVINGS MADE 323.8 1,027,492 £34,626

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SDI 20

GLOBAL REPORTING INITIATIVE (GRI)

Avon Metals is a voluntary participant in the Global Reporting Initiative - the world’s

most widely used sustainability reporting framework. The G3 Guidelines

(incorporating a Metals and Mining specific supplement developed by the

International Council for Metals and Mining) have become the de facto global

standard for reporting, and include financial, environmental and social dimensions

relating to the company's activities, products and services. GRI collaborates with the

United Nations Environment Programme (UNEP), and the United Nations Global

Compact . Our Index Reporting is made available to stakeholders through our

corporate website and hardcopy Annual Sustainability Report. In 2008, Avon Metals

became an Organisational Stakeholder of the GRI, reinforcing our commitment to

change.

“Our 20/20 Vision” Sustainability Report 2010 was developed with reference to the

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GRI APPLICATION LEVEL

This Sustainability Report was prepared with reference to the Global Reporting

Initiative 2002 Guidelines.

“Our 20/20 Vision” Sustainability Report 2010 was developed with reference to the

performance indicators listed as core elements in the Global Reporting Initiative

(GRI) G3 Sustainability Reporting Guidelines (October 2006) and the GRI Mining and

Metals Sector Supplement (Pilot Version 1.0, 2005). Here we have provided a

summary index for our Sustainability against each of the GRI guidelines. We have

self-declared our report as meeting the criteria for Application Level A and GRI have

checked and agreed Level A status.

NOTE: NC indicates a non-core indicator. MM indicates Mining and Metals sector

indicator.

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GRI

Section

GRI Description ICMM

Principle

Location

Strategy and Analysis

1.1 Statement from the most senior

decision-maker of the

organization about the

relevance of sustainability to

the organization and its

strategy.

2 Page 4 of “Our 20/20 Vision”

Sustainability Report.

1.2 Description of key impacts,

risks, and opportunities.

4 Description of key impacts, risks and opportunities

Key impacts on sustainability

Positives: - Strong progression in developing recycling rates with Alupro and other associations. Major reduction in volumes to land fill and/ or incineration

Negatives: - Emissions to air, noise pollution, increase in energy costs, reprocessing of by –products, investment required

Approach – PrioritiesThe need to continue to maximise stakeholder investment, continue working with other groups to insure progression in overall recycling rates, investment required in energy efficient processing and production burner equipment, although

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GLOBAL REPORTING INITIATIVE (GRI)

production burner equipment, although already very low – improve reusable/ recycling of industrial waste

Conclusions on progressNeed to lobby stakeholders for more investment but balance against returns. Continue efficiency initiatives underpinned by on-going training by lean manufacturing specialists. Reasons for underperformance –capital expenditure, new legislation eg. REACH,

Controls/ monitoringUnder new systems developed through lean manufacturing techniques, the mapping of critical issues are monitored, recorded and constantly worked on to drive a continuous improvement programme. In the medium to long term there is an opportunity to make more meaningful reductions in overall energy usage and improvements in efficiencies but this will require more commitment from stakeholders to allow the investment necessary.

Risks & Opportunities arising from sustainability trends

Risks – Rising energy costs. Rising transport costs. Increasing environmental controls and monitoring, increasing overheads and lowering profitability.

Opportunities - Development of Grant Funding

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Organisational Profile

2.1 Name of the organization. 10 Avon Metals Ltd

2.2 Primary brands, products,

and/or services.

10 Aluminium ingots – brand “AVON”, non-

ferrous scrap metal and specialty minor

metals.

2.3 Operational structure of the

organization, including main

divisions, operating

companies, subsidiaries, and

joint ventures.

10 Avon Metals is 100% privately owned by

The Remet Company and the Reid

Family. See Page 77 of our “Our 20/20

Vision” Sustainability Report.

2.4 Location of organization’s

headquarters.

10 Avon Metals Ltd, Ashville Road, Gloucester, GL2 5DA

2.5 Number of countries where

the organization operates,

and names of countries with

either major operations or

that are specifically relevant

to the sustainability issues

covered in the report.

10 1 – United Kingdom

2.6 Nature of ownership and legal

form.

10 Privately owned by The Remet Company

Ltd and the Reid Family. Established in

2001.

2.7 Markets served. 10 Aluminium casting companies, aluminium

rolling mills and extruders, titanium

producers, copper alloy producers,

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superalloy producers, steel and stainless

steel producers, electronics industry,

silicones industry, powder metallurgy

2.8 Scale of the reporting

organization.

10 Scale of reporting organisation as at

30.6.10: -

Number of employees = 42

Net sales = £40,664,000

Total capitalisation

Debt = £4,955,000

Equity = £40,664,000

Quantity of products provided

Manufactured product – 11,268 tonnes

Traded products = 6,540 tonnes

2.9 Significant changes during

the reporting period

regarding size, structure, or

ownership

10 None.

2.10 Awards received in the

reporting period.

10 Page 76 of “Our 20/20 Vision”

Sustainability Report

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Report Parameters

3.1 Reporting period. 10 Avon Metals’ sustainability reporting is on a

continuous basis. The Avon Sustainability

Report highlights our 2006-2010

performance.

3.2 Date of most recent previous

report.

10 2009

3.3 Reporting cycle. 10 Avon Metal’s sustainability reporting is on a

continuous basis. The Avon Sustainability

Report covers our annual performance.

3.4 Contact point for questions

regarding the report or its

contents.

10 Steven Munnoch, Managing Director

3.5 Process for defining report content. 10 “Our 20/20 Vision” Sustainability Report

includes data from financial years 2006-

2010 .Many factors were considered in

determining the contents of this report,

including Avon’s main sustainability impacts

and opportunities, reporting activity within

our own industry, and external guidelines

such as the Global Reporting Initiative (GRI)

G3 Sustainability Reporting Guidelines. Our

stakeholders are the key groups of people

who influence the success and development

of our business and are detailed on pages

74-75 of our CSR Report.

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3.6 Boundary of the report. 10 Data contained in this reporting is for Avon

Metals’ facility.

3.7 State any specific limitations on

the scope or boundary of the

report.

10 The reporting is for Avon Metals’ facility.

3.8 Basis for reporting on joint

ventures, subsidiaries, leased

facilities, outsourced operations,

and other entities that can

significantly affect comparability

from period to period and/or

between organizations.

10 There are no joint ventures, subsidiaries,

leased facilities, outsourced operations, and

other entities that can significantly affect

comparability from period to period and/or

between organizations.

3.9 Data measurement techniques and

the bases of calculations, including

assumptions and techniques

underlying estimations applied to

the compilation of the Indicators

and other information in the

report.

10 Avon uses a variety of internal standards

and data collection systems, as well as a

rigorous internal and external audit process.

In addition, we conform to external data

reporting standards, such as British

Standards, and comply with government

bodies like the Environment Agency.

3.10 Explanation of the effect of any re-

statements of information provided

in earlier reports, and the reasons

for such re-statement.

10 Completion date for Carbon Neutral target

increased to 2020.

3.11 Significant changes from previous

reporting periods in the scope,

boundary, or measurement

methods applied in the report.

10 No significant changes from previous

report.

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3.12 Table identifying the location of

the standard disclosures in the

report.

10 The GRI Content Index can be found on

Page 50 of “Our 20/20 Vision”

Sustainability Report.

3.13 Policy and current practice with

regard to seeking external

assurance for the report.

10 “Our 20/20 Vision” Sustainability Report

follows the guidelines set out by the GRI.

All information contained has been

reviewed at senior levels and by all

departmental heads. undertakes a range of

audit and assurance on activities including

financial (auditors), packaging waste

(Environment Agency), environmental &

EHS (BSi management), customer

performance audits.

Governance, Commitments, and Engagement

4.1 Governance structure of the

organization.

1 Page 77 “Our 20/20 Vision” Sustainability

Report See flowchart “Corporate Structure”

4.2 Indicate whether the chair of the

highest governance body is also

an executive officer.

1 As of 2010, the chairman of the board is

also an executive officer. The Chairman of

the board is also an executive officer as he

is the owner of the business and chooses to

take an active role in the business which he

owns and operates.

4.3 For organizations that have a

unitary board structure, state the

number of members of the highest

1 Avon Metals does not have a unitary board

structure.

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governance body that are

independent and/or non-executive

members.

4.4 Mechanisms for shareholders and

employees to provide

recommendations or direction to

the highest governance body.

1 There are no formal mechanisms in place

for employees to also provide guidance or

recommendations to the highest

governance body. All employees and

minority shareholders are encouraged to

communicate any concerns to Avon Metals’

Board of Directors via the Managing

Director, who would confer with the

Chairman/Owner.

4.5 Linkage between compensation for

members of the highest

governance body, senior

managers, and executives

(including departure

arrangements), and the

organization’s performance

(including social and

environmental performance).

1 See Pages 28-30 of “our 20/20 Vision”

Sustainability Report. Directors & Managers

are a paid bonus based on profitability but

changing to reflect instability issues with

regards to the 20/20 Vision. Key personnel

are tied by long notice periods to ensure

continuity.

4.6 Processes in place for the highest

governance body to ensure

conflicts of interest are avoided.

1 Corporate Governance

Governance Guidelines

Governance and Nominating Committee

Anti-Bribery Policy

Whistle blowing Policy

4.7 Process for determining the

qualifications and expertise of the

members of the highest

governance body for guiding the

organization’s strategy on

economic, environmental, and

social topics.

1 Pages 28-30 of “Our Vision” Sustainability

Report.

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4.8 Internally developed statements of

mission or values, codes of

conduct, and principles relevant to

economic, environmental, and

social performance and the status

of their implementation.

1 Mission Statement – Page 3

Intro to Sustainability Philosophy – Page 4

UN Global Compact Principles – Pages 34-35

Human Rights & Core Values– Page 39-40

Anti-Bribery – Page 41

4.9 Procedures of the highest

governance body for overseeing

the organization’s identification

and management of economic,

environmental, and social

performance, including relevant

risks and opportunities, and

adherence or compliance with

internationally agreed standards,

codes of conduct, and principles.

1 Water Policies – Page 19

Global Compact Actions – Pages 35-36

Employees Rights – Page 40

Anti-Bribery – Page 42

4.10 Processes for evaluating the

highest governance body’s own

performance, particularly with

respect to economic,

environmental, and social

performance.

1 Corporate Governance

Governance Guidelines

Governance and Nominating Committee

GRI Verification

UN Global Compact

PACI

Shift Initiative

4.11 Explanation of whether and how

the precautionary approach or

principle is addressed by the

organization.

2 Through our extensive management

systems, we advocate a risk-based

approach to our operations. At this stage,

however, we do not formally address the

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organization. however, we do not formally address the

precautionary principle in our sustainability

reporting.

4.12 Externally developed economic,

environmental, and social charters,

principles, or other initiatives to

which the organization subscribes

or endorses.

1 We subscribe to or endorse the following

externally developed principles or initiatives:

• UN Global Compact (Page 34-38.

• World Economic Forum Partnership

Against Corruption Initiative (Pages

39-42).

• International Aluminium Institute

Sustainability Principles.

• International Council on Mining &

Metals Principles

4.13 Memberships in associations (such

as industry associations) and/or

national/international advocacy

organizations.

1 • Aluminium Federation (ALFED)

• British Metals Recycling Association

(BMRA)

• Cast Metals Federation (CMF)

• Minor Metals Trade Association

(MMTA)

• Aluminium Packaging Recycling

Organisation (AluPRO)

• International Titanium Association

(ITA)

• Beacon South West

• Gloucestershire Wildlife Trust

• Gloucestershire Ambassadors

• Slimbridge Wildfowl & Wetlands

Trust

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4.14 List of stakeholder groups

engaged by the organization.

10 Pages 69-71 of “Our 20/20 Vision”

Sustainability Report

• Customers

• Raw material providers

• Service providers

• Members of staff

• Aluminium Federation

• Cast Metal Federation

• Minor Metals Trade Association

• ALUPRO

• Beacon South West

• Local Police Force

• Local companies

4.15 Basis for identification and

selection of stakeholders with

whom to engage.

10 Avon Metal engages with a wide range of

stakeholders . Stakeholders were identified

during the planning process for the

publication of “Our 20/20 Vision” as those

groups that may be significantly impacted,

positively of negatively, by Avon Metals’

products, services and activities.

see Pages 73-75 of “Our 20/20 Vision”

Sustainability Report

4.16 Approaches to stakeholder

engagement, including frequency

of engagement by type and by

stakeholder group.

10 Pages 73-75 of “Our 20/20 Vision”

Sustainability Report

SDI 20

GLOBAL REPORTING INITIATIVE (GRI)

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 5 5

stakeholder group.

4.17 Key topics and concerns that have

been raised through stakeholder

engagement, and how the

organisation has responded to

those key topics and concerns,

including through its reporting.

10 Pages 69-71 of “Our 20/20 Vision”

Sustainability Report

Disclosure on Management Approach – Economic

Goals & Performance

Goals related to the economic aspects are set and

performance measured against company specific

indicators tracking impacts to society and stakeholders.

PolicyPages 43-48 of “Our 20/20 Vision” Sustainability

Report

Organisational Responsibility Our organizational structure is detailed on page 74 of

our 20/20 Vision Sustainability Report

Training & Awareness Encouraged 4 members of ICME + specific training

Monitoring and Follow-up Clear reporting + Regular meetings

Additional Information Key successes – doubling of profits year on year,

Queens Award for International Trade in 2010, local

door trade contributed £1.6 million per annum to

Gloucestershire economy

Risks – Declining demand for consumer goods in tough

economic climate, stiff competition from cheaper

aluminium producers such as China, India and eastern

Europe.

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Performance Indicators—Economic

EC1 Direct economic value

generated and

distributed, including

revenues, operating

costs, employee

compensation, donations,

and other community

investments, retained

earnings, and payments

to capital providers and

governments.

9 Page 47 & 76 of “Our 20/20 Vision” Sustainability Report

EC2 Financial implications and

other risks and

opportunities for the

organization’s activities

due to climate change.

9 Avon Metals’ Senior Management is engaged in the

implications and opportunities related to the issue of

climate change. Avon Metals commits to investing a

significant portion of its Research and Development

budget to support and develop alternative energy and

less carbon-intensive raw material sources, including

solar photovoltaics. We are examining the way our

products are made and constantly seeking opportunities

to utilise new process technologies that substantially

reduce the carbon consumed as energy inputs or that is

released during the manufacture of our products. We

have not yet quantified these risks and opportunities in

detail, as we believe that the risks and opportunities to

our business are currently too small to justify

SDI 20

GLOBAL REPORTING INITIATIVE (GRI)

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 5 6

committing valuable management time and resources.

EC3 Coverage of the

organization’s defined

benefit plan obligations.

9 The structure of retirement plans offered to employees

are base on “other types of benefit”. A stakeholder

retirement scheme has been established providing

benefits based upon individual accumulated funds. The

employer contributes individually agree amounts to the

fund of each member. Employees are entitled to make

undefined contributions to their fund, subject to the rules

of the scheme. Only a few senior employees are known

to benefit from company contributions. No employees

contributions are made through the company and it is

not known if employees are contributing directly to their

scheme funds.

EC4 Significant financial

assistance received from

government.

9 None

EC6 Policy, practices, and

proportion of spending

on locally-based

suppliers at significant

locations of operation.

9 Wherever possible Avon Metals endeavours to support

the local economy and employ the services of

Gloucestershire based companies including haulage

contractors, IT specialists, plant maintenance engineers

& printers amongst others, however we do not have a

specific policy in place for preferring locally based

suppliers. Our geographic definition of “local” means

within 5 miles of our company. Factors that indicate our

supplier selection include: cost, reputation, reliability,

reduction of carbon footprint by using local companies,

convenience, response time. Avon Metals source makes

purchases from all over the world , directly from

countries where the product is mined/extracted.

Therefore, as a percentage of overall spend, our local

purchases are minimal and account for less than 1% per

annum.

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EC7 Procedures for local hiring and

proportion of senior management

hired from the local community at

locations of significant operation.

9 The company does not have a global policy or

common practices for granting preference to

local residents when hiring in significant

locations of operation. The proportion of senior

management hired from the local community is

currently 100%.

EC8 Development and impact of

infrastructure investments and

services provided primarily for public

benefit through commercial, in-kind,

or pro bono engagement.

9 Pages 20 of “Our 20/20 Vision” Sustainability

Report .

MM1 Identify those sites where the local

economic contribution and

development impact is of particular

significance and interest to

stakeholders and outline policies with

respect to assessing this contribution.

9 Pages 73-75 of “Our 20/20 Vision”

Sustainability Report

Disclosure on Management Approach - Environmental

Goals & Performance Avon Metals are committed to minimizing the

environmental impact of our operations and our

products through the adoption of sustainable

practices and continuous improvement in

environmental performance. We manage our

performance against clear and objective criteria,

setting targets for improvement and then monitor,

review and report against these targets.

SDI 20

GLOBAL REPORTING INITIATIVE (GRI)

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 5 7

Sustainable Development Indicators (SDIs) have

been developed with quantifiable targets to

improve our regulatory compliance and

environmental control procedures, to reduce our

CO2 emissions per tonne of aluminium product, to

reduce waste landfill and energy and water

consumption, to increase recycling rates and to

improve the environment within which we operate.

Policy Our Environmental Policy is communicated online

via our corporate website www.avonmetals.com

Organisational Responsibility Our organizational structure is detailed on page 77

of “Our 20/20 Vision” Sustainability Report

Training & Awareness Training is carried out within the guidelines and

framework of our ISO 14001 Environmental

Management System.

Monitoring and Follow-up Avon Metals’ operates an environmental

management system certified to the ISO 14001

standard, with internal and external audits of

compliance.

Additional Information Key successes – implementation of ISO 14001,

reduction in Greenhouse Gases, corporate

sponsorship of Gloucestershire Wildlife Trust and

Slimbridge Wildfowl & Wetlands Trust.

Risks – REACH legislation, Climate Change

A recent study by the Carbon Trust identified areas

for improvement and these are detailed on page 48

of “Our 20/20 Vision” Sustainability Report

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EN1 Materials used by

weight or volume.

6 2010 tonnages:-

• Primary Aluminium = 1392 tonnes

• Aluminium Scrap = 8359 tonnes

• Aluminium packaging waste = 437 tonnes

• Alloying elements = 1912 tonnes

EN2 Percentage of

materials used

that are recycled

input materials.

6 2010 = 76% 2007 = 74%

2009 = 76%

2008 = 74%

EN3 Direct energy

consumption by

primary energy

source.

6 Direct Non-Renewable Energy Sources

Coal = NIL

Natural Gas = 36,000 Giga Joules per annum

--------------------------------------------------------------------

Direct Renewable Energy Sources

Biofuels = NIL

Ethanol = NIL

Hydrogen = NIL

---------------------------------------------------------------------

Direct energy sources produced = NIL

Direct energy sources sold = NIL

Total direct energy consumption = 61,200 GJ per annum

Total direct renewable energy consumption = NIL

Total direct non-renewable direct energy consumption =

61,200 Gig Joule per annum

EN4 Indirect energy

consumption by

6 Intermediate energy purchased and consumed from non-

renewable energy sources: -

SDI 20

GLOBAL REPORTING INITIATIVE (GRI)

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 5 8

consumption by

primary source.

renewable energy sources: -

Gigajoules

Electricity 25,200 per annum

Heating and Cooling NIL

Steam NIL

Nuclear Energy NIL

Other forms of imported energy NIL

--------------------------------------------------------------------------------------------

---

Intermediate energy purchased and consumed from

renewable energy sources: -

Gigajoules

Solar NIL

Wind NIL

Geothermal NIL

Hydro energy NIL

Biomass -based NIL

Hydrogen-based NIL

The total amount of indirect energy used by indirect non-

renewable sources and indirect renewable sources in terms of

intermediate energy = 25,200 Gigajoules for 2010. From

informal discussions with our electricity provider, we estimate

that 1 Gigajoule of electrical energy requires 2.5 Gigajoules

of primary energy. Therefore approx. 63,000 Gigajoules of

primary energy are used to generate the intermediate energy

we purchase – this excess is due to grid and efficiency losses

when converting and transporting energy.

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EN5

NC

Energy saved due to

conservation and

efficiency improvements.

6 Pages 16-22 of “Our 20/20 Vision” Sustainability Report

EN6

NC

Initiatives to provide

energy-efficient or

renewable energy based

products and services,

and reductions in energy

requirements as a result

of these initiatives.

6 Pages 16-22 of “Our 20/20 Vision” Sustainability Report

EN7

NC

Initiatives to reduce

indirect energy

consumption and

reductions achieved.

6 See EN6 NC

EN8 Total water withdrawal

by source.

6 Pages 21 of “Our 20/20 Vision” Sustainability Report

EN10

NC

Percentage and total

volume of water recycled

and reused.

6 Pages 16-22 of “Our 20/20 Vision” Sustainability Report

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SDI 20

GLOBAL REPORTING INITIATIVE (GRI)

EN11 Location and size of land

owned, leased, managed

in, or adjacent to,

protected areas and

areas of high biodiversity

value outside protected

areas.

7 The company operations are not located in or near

protected areas or areas of high biodiversity value.

However, the company is keen to promote biodiversity

and conservation of wildlife on a regional level and to

this end we are corporate partners and sponsors of

Slimbridge Wildfowl and Wetlands Trust and

Gloucestershire Wildlife Trust. The work we engage in

with these valued business partners is detailed in Page

15 of “Our 20/20 Vision” Sustainability Report.

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 5 9

EN12 Description of significant

impacts of activities,

products, and services on

biodiversity in protected

areas and areas of high

biodiversity value outside

protected areas.

7 The company is not aware of events in the period of

reporting causing significant negative impacts on

biodiversity in protected areas or areas of high

biodiversity value.

EN13

NC

Habitats protected or

restored.

7 Page 15 of “Our 20/20 Vision” Sustainability Report.

Avon helps to protect and restore local habitats

through our corporate membership of Gloucestershire

Wildlife Trust.

EN14

NC

Strategies, current

actions, and future plans

for managing impacts on

biodiversity.

7 Page 15 of “Our 20/20 Vision” Sustainability Report.

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EN15

NC

Number of IUCN Red List

species and national

conservation list species

with habitats in areas

affected by operations,

by level of extinction

risk.

7 None.

EN16 Total direct and indirect

greenhouse gas

emissions by weight.

6 Page 5 of “Our 20/20 Vision” Sustainability Report.

Direct Greenhouse Gas (GHG) emissions

Carbon Dioxide (CO2):

• 2010 = 2.38 mg/m3

• 2009 = 2.38 mg/m3

• 2008 = 2.38 mg/m3

• 2007 = 15.8 mg/m3

• 2006 = 31 mg/m3

In the period of reporting we have reduced our Carbon

Dioxide emissions by 92%.

Avon Metals is not a significant generator of the direct

Greenhouse gases Methane, Hydrofluorocarbons

(HFCs), Perfluorocarbons (PFCs) or Sulphur

hexafluoride (SF6).

SDI 20

GLOBAL REPORTING INITIATIVE (GRI)

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 6 0

Indirect Greenhouse Gas (GHG)emissions

Carbon Monoxide (CO):

• 2010 = 2.38 mg/m3

• 2009 = 2.38 mg/m3

• 2008 = 2.38 mg/m3

• 2007 = 3.9 mg/m3

In the period of reporting we have reduced our Carbon

Monoxide emissions by 39%.

EN17 Other relevant indirect

greenhouse gas

emissions by weight.

6 Page 5 of “Our 20/20 Vision” Sustainability Report.

Sulphur Oxide and Nitrogen Oxide data is detailed in

EN20. Carbon Monoxide data is detailed in EN16. Avon

Metals is not a significant generator of other indirect

greenhouse gases such as Non-methane volatile

organic compounds (NMVOCs).

EN19 Emissions of ozone-

depleting substances by

weight.

6 Page 5 of “Our 20/20 Vision” Sustainability Report.

Avon Metals is not a significant generator of ozone

depleting CFC (chlorofluorocarbon) gases.

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EN20 NO, SO, and

other

significant air

emissions by

type and

weight.

6 Page 5 of “Our 20/20 Vision” Sustainability Report.In the period of reporting 2006 – 2009 Avon Metals have reduced

Nitrogen Oxide emissions by 93% and Sulphur Oxide emissions by 29%.

Nitrogen Oxide Emissions (NOx):• 2010 = 2.28 mg/m3 2006 = 31 mg/m3• 2009 = 2.28 mg/m3• 2008 = 2.28 mg/m3• 2007 = <5 mg/m3

Sulphur Oxide Emissions (SOx):• 2010 = 2.9 mg/m3 2007 = 4.1 mg/m3• 2009 = 2.9 mg/m3• 2008 = 2.9 mg/m3

In addition since we also report on the following other significant air emissions: -Cadmium and its compounds

• 2010 = 0.015 mg/m3 2007 = 0.007 mg/m3• 2009 = 0.015 mg/m3• 2008 = 0.015 mg/m3Lead and its compounds – permissible max. limit = 1 mg/m3

• 2010 = 0.010 mg/m3 2006 = 0.10 mg/m3• 2009 = 0.010 mg/m3• 2008 = 0.010 mg/m3• 2007 = 0.018 mg/m3Chloride (as HCl) – permissible max. limit = 5 mg/m3

• 2009 = 1.38 mg/m3• 2008 = 1.38 mg/m3• 2007 = 1.08 mg/m3• 2006 = 2.19 mg/m3Fluoride (as HF) – permissible max. limit = 5 mg/m3

• 2010 = 0.430 mg/m3 2006 – 0.23 mg/m3• 2009 = 0.430 mg/m3• 2008 = 0.430 mg/m3• 2007 = 0.14 mg/m3

Total particulate matter – permissible max. limit = 209mg/m3

• 2010 = 3.605 mg/m3 2006 = 9.47 mg/m3• 2009 = 3.605 mg/m3

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GLOBAL REPORTING INITIATIVE (GRI)

• 2009 = 3.605 mg/m3• 2008 = 3.605 mg/m3• 2007 = 2.62 mg/m3

In most cases improvements have been made and our emissions

our well below the statutory levels imposed under our Permit to

Operate.

EN21 Total water

discharge by

quality and

destination.

6 Avon Metals is dedicated to implementing innovative ways to

conserve water, including rainwater capture, and identifying by-

product synergy opportunities to reuse the water for beneficial

purposes. A large proportion (70%) of the water we use on site is

for cooling down molten metal and this water evaporates into the

atmosphere. The remaining 30% passes through our interceptor

tanks to remove any solid matter or oils before being discharged

into the foul sewers. Severn Trent Water have assessed our site

and have confirmed that the water we discharge is 100% safe to

return to the water course and we receive a 90% reduction on our

sewage levy as an incentive to maintain this process.

Water Discharges (estimated)

Evaporated water from cooling molten metal:

• 2010 = 3725 m3 2006 = 2631 m3

• 2009 = 2891 m3

• 2008 = 3527 m3

• 2007 = 3180 m3

Water discharged into the foul sewer:

• 2010 = 1596 m3 2006 = 1127 m3

• 2009 = 1239 m3

• 2008 = 1512 m3

• 2007 = 1364 m3

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SDI 20

GLOBAL REPORTING INITIATIVE (GRI)

EN22 Total weight of waste by type and

disposal method.

6 Total weight of waste by type and disposal

method for 2010. All the waste that Avon Metals

generates is non hazardous. The method of

disposal has been determined from information

provided to us by our waste disposal contractor.

Material Weight (kgs) Disposal

Dross 828,000 100% recycled

Concrete 32,940 100% recycled

Hardcore (rubble) 159,820 100% recycled

Road Dig 305,240 100% recycled

A Grade Packing Wood 99,940 100% recycled

Cardboard 2,070 100% recycled

General Waste 163,500 85% recycled

EN23 Total number and volume of

significant spills.

6 No significant spills occurred within the reporting

period.

EN24

NC

Weight of transported, imported,

exported, or treated waste deemed

6 Avon Metals adheres to the strictest

environmental standards and laws for the

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NC exported, or treated waste deemed

hazardous under the terms of the

Basel Convention Annex I, II, III,

and VIII, and percentage of

transported waste shipped

internationally.

environmental standards and laws for the

transport of hazardous waste.

In the period of reporting we did not

import/export any hazardous waste.

EN26 Initiatives to mitigate

environmental impacts of products

and services, and extent of impact

mitigation.

8 Pages 11, 42-45 of “Our 20/20 Vision”

Sustainability Report

EN27 Percentage of products sold and

their packaging materials that are

reclaimed by category.

8 Data on the percentage of products sold and their packaging materials reclaimed by category is not available on a global level due to the varying availability of recycling programs and facilities in the countries in which we sell our products.

EN28 Monetary value of significant fines

and total number of non-monetary

sanctions for noncompliance with

environmental laws and

regulations.

6 Avon Metals’ goal is 100% compliance with all

environmental laws and regulations.

There were no fines in the reporting period.

EN30

NC

Total environmental protection

expenditures and investments by

type.

6 DISA Airmaster to control stack emissions £100k.

New furnaces to improve recycling recovery rates

£500k

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MM3 The number/percentage of sites

identified as requiring biodiversity

management plans, and the

number/percentage of sites with

plans in place. Also include criteria

for deciding that a biodiversity

management plan is required and

the key components of a plan.

7 We do not have a specific biodiversity

management plan. Biodiversity is controlled

under our ISO 14001 Environmental

Management System and our co-ordination with

Gloucestershire Wildlife Trust and Slimbridge

Wildfowl and Wetlands Trust.

MM4 Percentage of product(s) derived

from secondary materials.

8 2010 = 76% 2007 = 74%

2009 = 76%

2008 = 74%

MM5 Describe policies for assessing the

eco-efficiency and sustainability

attributes of products.

8 Page 43-46 of “Our 20/20 Vision” Sustainability

Report

MM6 Describe approach to management

of overburden, rock, tailings, and

sludges/residues.

7 The dross or skimming’s that are created in our

smelting process are sent away for refining at a

specialist plant in Shropshire, where any useful

metal content is extracted and machined in re-

meltable metallic balls and the leftover salt cake

is sold into the refractory and brickwork

industries to make useful building and ceramic

based products, due to the organic content.

Page 8 of “Our 20/20 Vision” Sustainability

Report

SDI 20

GLOBAL REPORTING INITIATIVE (GRI)

Goals & Performance Avon Metals wants to be a challenging work place based

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 6 3

on trust, respect, inclusion, and with a healthy and safe

working environment.

Policy Our Health & Safety policy forms part of our statutory

information given to all employees as part of their

Employee Handbook and Terms & Conditions of

Employment.

United Nations Declaration of Human Rights.

ILO Declaration on Fundamental Principles and Rights at

Work of 1998 (core conventions)

Organisational Responsibility Our organizational structure is detailed on page 77 of

“Our 20/20 Vision” Sustainability Report

Training & Awareness Training is carried out in line with OHSAS 18001 protocol

including: -

• Work-life balance and lifelong learning

• Individual development plans for all

• Diversity in the workplace

• Continuous focus on Occupational Health and

Safety

Publishing of 20/20 Vision to stakeholders.

Monitoring and Follow-up Procedures related to monitoring and corrective and

preventative actions are carried out in line with OHSAS

18001 standard, to which we intend to be accredited to

by British Standards in 2011 and will be audited

accordingly.

Additional Information Key successes – UN Global Compact signatory, Zero

Fatality Rate.

Risks – retaining competent staff.

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Disclosure on Management Approach – Labour practices and Decent Work

Performance Indicators—Labor Practices and Decent Work

LA1 Total workforce by

employment type,

employment contract, and

region.

3 Page 30 of “Our 20/20 Vision” Sustainability Report.

Total Avon Workforce:

52 employees at July 2010

Breakdown by Employment Type:

100% of all Avon employees are full time.

Breakdown by Employment Contract:

100% of Avon employees are permanently contracted.

Region:

100% employed in Gloucester, UK.

LA2 Total number and rate of

employee turnover by age

group, gender, and

region.

3 Avon Metals believes that its people are its most valuable

asset and aims to create safe and sustainable

employment conditions. Staff turnover is much lower than

the local average at less than 5% per annum during the

four year period of reporting. Avon does not release

employee turnover data by age group, gender or region

for proprietary and competitive reasons.

LA4 Percentage of employees

covered by collective

bargaining agreements.

3 Nil.

LA5 Minimum notice period(s)

regarding operational

3 Our practice is to give notice as early as possible and

cooperate with the employee representatives. We have no

SDI 20

GLOBAL REPORTING INITIATIVE (GRI)

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regarding operational

changes, including

whether it is specified in

collective agreements.

cooperate with the employee representatives. We have no

collective agreements in place.

LA6

NC

Percentage of total workforce

represented in formal joint

management–worker health and

safety committees that help

monitor and advise on occupational

health and safety programs.

5 Avon Metals has several trained health and

safety representatives who participate in

deployment of the location’s proactive safety

efforts.

LA7 Rates of injury, occupational

diseases, lost days, and

absenteeism, and number of work-

related fatalities by region.

5 Page 27 of “Our 20/20 Vision” Sustainability

Report.

The occupational disease rate (ODR) for the

period of reporting was zero.

Absenteeism rate (AR) = the number of

days of absence from work (excluding leaves

for vacations, family reasons, study, and

maternity or paternity) , which was 130 in

2010, compared to the total number of days

worked, 14,250 and multiplied by 100 =

0.91%.

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prevention, and risk-control

programs in place to assist

workforce members, their families,

or community members regarding

serious diseases.

5 Pages 23-29 of “Our 20/20 Vision”

Sustainability Report

LA9

NC

Health and safety topics covered in

formal agreements with trade

unions.

2 Avon Metals has several trained health and

safety representatives who participate in

deployment of the location’s proactive safety

efforts.

LA10 Average hours of training per year

per employee by employee

category.

2 Training and education varies by job role

and responsibilities. On average, there are

approximately 50 hours of training per

employee. Avon Metals has extensive

training programs for employees involved in

every job category. See Pages 28 and 29 of

“Our 20/20 Vision” Sustainability Report.

LA11

NC

Programs for skills management

and lifelong learning that support

the continued employability of

employees and assist them in

managing career endings.

2 Pages 28-29 of “Our 20/20 Vision”

Sustainability Report

LA12

NC

Percentage of employees receiving

regular performance and career

development reviews.

3 100%. Page 14 of “Our 20/20 Vision”

Sustainability Report.

LA13 Composition of governance bodies

and breakdown of employees per

category according to gender, age

3 Page 30 of “Our 20/20 Vision” Sustainability Report. Our company structure may be

found on page74 of “Our 20/20 Vision” Sustainability Report. Avon Metals’ aims to

SDI 20

GLOBAL REPORTING INITIATIVE (GRI)

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 6 5

category according to gender, age

group, minority group

membership, and other indicators

of diversity.

Sustainability Report. Avon Metals’ aims to

create a diverse multi-national, multi-skilled workforce. Our workforce is displayed below by Diversity Indicators (gender,, minority, age):

The following provides diversity indicators for the main employee population.By gender:• Male 93 %• Female 7 %By minority (ethnicity, disability etc):• Minority 49 %• Non-minority 51 %By age:• Less than 30: 31 %• 30 to 50: 42 %

• Older than 50: 27 %

The following provides diversity indicators for the individuals within the organization’s governance body: -By gender:• Male 100 %• Female 0 %By minority (ethnicity, disability etc):• Minority 0 %• Non-minority 100 %By age:• Less than 30: 0 %• 30 to 50: 40 %

• Older than 50: 60 %

LA14 Ratio of basic salary of men to

women by employee category.

3 Page 14 of “Our 20/20 Vision” Sustainability Report.The average base salary by gender:• Male £22,000 per annum• Female £19,000 per annum

The ratio of male to female average base salary in 2010 was 1.16 : 1

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Disclosure on Management Approach – Human Rights

Goals & Performance Avon Metals prides itself on its reputation as a fair

and ethically run business. We aim to earn the

trust and respect of the businesses and people

within our sphere of influence, through our core

values of transparency, accountability, integrity,

solidarity, courage, justice & democracy

Policy Our Human Rights Policy and Human Rights

Statement reflect internationally recognized

principles – including the United Nations Global

Compact and the Universal Declaration of Human

Rights and the International Labor Organisation’s

Declaration on Fundamental Principles and Rights

at Work – to promote and protect human rights in

the workplace. We abhor human right abuses and

child labour and have a “zero tolerance” attitude

to these issues.

Organisational Responsibility Our organizational structure is detailed on page

77 of “Our 20/20 Vision” Sustainability Report.

Training & Awareness Training is given in line with guidelines laid down

by the United Nations Global Compact and the

Universal Declaration of Human Rights.

Monitoring & Follow-up See United Nations Global Compact

Additional Information Key successes -Avon Metals is a signatory to the

SDI 20

GLOBAL REPORTING INITIATIVE (GRI)

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 6 6

Additional Information Key successes -Avon Metals is a signatory to the

World Forums Partnering Against Corruption

Initiative

Risks – future suppliers in regions such as China

may not have equivalent Human Rights

standards.

Performance Indicators—Human Rights

HR1 Percentage and total number of

significant investment agreements

that include human rights clauses or

that have undergone human rights

screening.

3 Human rights screening is a part of our

environmental and social impact

assessments, which are conducted in the

early phase of all major projects. During the

period of reporting, there were no large

investment agreements that included human

rights clauses or that have required human

rights screening.

HR2 Percentage of significant suppliers

and contractors that have undergone

screening on human rights and

actions taken.

3 100%. No actions were required to be taken.

Pages 39-42 of “Our 20/20 Vision”

Sustainability Report.

HR4 Total number of incidents of

discrimination and actions taken.

3 There were no incidents of discrimination

during the reporting period.

HR5 Operations identified in which the

right to exercise freedom of

association and collective bargaining

may be at significant risk, and actions

taken to support these rights.

3 Page 40 of “Our 20/20 Vision” Sustainability

Report.

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Disclosure on Management Approach - Social

Goals & Performance Avon Metals are committed to conducting our business in a

way that ensures health and wellbeing of our employees,

contractors and any person affected by our activities. We do

not tolerate corrupt or fraudulent practices and expect

transparency, integrity and honesty in all aspects of our

business, from our employees, contractors and other

business counterparts. We aim to play a positive role in the

communities and societies within which we operate,

promoting and encouraging economic, environmental, social

and educational development where possible. Avon Metals

wants to be a responsible corporate neighbour in the

communities in which we operate. We strive to integrate this

objective in the way we work, through all our business

processes and our products. We operate on the basis of high

business integrity standards and have clear guidelines for

SDI 20

GLOBAL REPORTING INITIATIVE (GRI)

HR6 Operations identified as having

significant risk for incidents of child

labor, and measures taken to

contribute to the elimination of child

labor.

3 We have identified that our operation is not at

risk of employing child labour.

HR7 Operations identified as having

significant risk for incidents of forced

or compulsory labor, and measures to

contribute to the elimination of forced

or compulsory labor.

3 Our single site operation has been identified as

having zero significant risk for incidents of

forced or compulsory labour.

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 6 7

business integrity standards and have clear guidelines for

donations and influencing public policy.

Policy Our Anti Bribery & Corruption Policy is detailed on pages 39-

42 of “Our 20/20 Vision” Sustainability Report and follows

guidelines laid down by the World Economic Forum’s

Partnership Against Corruption Initiative.

UN Global Compact

Whistleblowing Policy

Harassment & Bullying Policy

Organisational Responsibility Our organizational structure is detailed on page 74 of “Our

20/20 Vision” Sustainability Report.

Training & Awareness Avon Metals' training & awareness measures have not been

devised to correct bad behavior, but instead to further

galvanise our values of accountability, responsibility and

openness and honesty. As a means of ensuring effective

implementation, we have developed training material and

continue to train selected employee groups. Furthermore, all

employees have access to guidance and a means to raise

concern about possible breaches of our integrity principles

anonymously.

Monitoring and Follow-up Confidential mechanisms for employees to report issues of

concern are in place. A formal investigative process is in

place to respond to reports of corruption. Managed by the

Managing Director, the Chairman and a senior representative

from the relevant department.

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GLOBAL REPORTING INITIATIVE (GRI)

Additional Information Key successes – becoming a signatory to the UN Global Compact and PACI

Initiatives. Introduction of Whistleblowing & Harassment & Bullying Policies.

Risks - our governing policies and procedures relating to the social issues

covered in this section provide us with assurances to minimise risks in these

areas.Performance Indicators—Society

SO1 Percentage of operations with

implemented local community

engagement, impact assessments, an

development programmes.

2, 4 Total number of operations = 1. Environmental

impact assessments and ongoing monitoring are

carried out in line with ISO 9001 and ISO 14001

standards. See pages 31-33 Improvement of

Community Relations and pages 72-74 Stakeholder

Engagement.

We believe in giving something back to the many

communities we work in: building links with local

businesses, supporting our people in their own

neighbourhoods and reinforcing our reputation as a

responsible company. We give our skills and our time,

as well as money to supporting people volunteering

and fundraising projects. See pages 95 & 30-32 of

“Our 20/20 Vision” Sustainability Report

SO2 Percentage and total number of

business units analysed for risks related

to corruption.

1 100% . Our Anti Bribery and Corruption policy has

been developed and disseminated in accordance with

the World Economic Partnership’s PACI Initiative. See

pages 39-42.

SO3 Percentage of employees trained in

organisation’s anti-corruption policies

and procedures.

1 100% of our 52 employees (5 management and 47

non-management employees) have received anti-

corruption training during the reporting period.

SO4 Actions taken in response to incidents 1 There were no incidents of anti-corruption within the

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 6 8

SO4 Actions taken in response to incidents

of anti-corruption.

1 There were no incidents of anti-corruption within the

reporting period, and therefore no action was

required to be taken in response. There were no

incidents when contracts with business partners were

not renewed due to violations related to corruption.

There were no legal cases regarding corrupt practices

brought against the company or its employees during

the reporting period.

SO5 Public policy positions and participation

in public policy development and

lobbying.

1 Avon Metals’ senior Management has developed

relationships with key government stakeholders,

policy influencers, NGOs and trade and business

associations who impact Avon’s interests and business

concerns. We have therefore been indirectly involved

in lobbying on topics such as Climate Change, REACH

legislation through our membership of trade

associations such as the Aluminium Federation and

the Minor Metals Trade Association.

SO6 Total value of financial and in-kind

contributions to political parties,

politicians, and related institutions by

country.

1 Zero

SO7 Total number of legal actions for anti-

competitive behaviour and anti-trust,

and monopoly practices and their

outcomes.

1 Zero

SO8 Monetary value of significant fines and

total number of non-monetary

sanctions for non-compliance with laws

and regulations,

1 Zero

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MM10 Number or percentage of

operations with closure plans,

covering social—including labor

transition—environmental and

economic aspects. Describe

company policy, stakeholder

engagement processes, frequency

of plan review, and amount and

type of financial provisions for

closure.

2 N/A

MM11 Describe process for identifying

local communities’ land and

customary rights, including those

of indigenous peoples, and

grievance mechanisms used to

3 During 2006-2010 inclusive there were no

reports of violations involving rights of

indigenous people received in relation to

Avon Metals’ operations.

SDI 20

GLOBAL REPORTING INITIATIVE (GRI)

Describe program in which the reporting

organization has been involved that

addressed artisanal and small-scale

mining (ASM) within company areas of

operation.

9 N/A. There is no artisanal or small scale

mining conducted within our area of

operation.

Describe resettlement policies and

activities.

3 N/A

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 6 9

resolve any disputes.

MM12 Describe approach to identifying,

preparing for, and responding to

emergency situations affecting

employees, communities, or the

environment.

4 Emergency management is part of our

management systems that require all

operations to have emergency response

plans, and to conduct ongoing skills training

and exercises to assess their workers'

readiness to respond to actual

emergencies. The primary response

techniques and training are for such things

as molten metal splashes, handling

hazardous materials, firefighting and

providing agreed-upon local aid.

MM13 Number of new cases of

occupational disease by type.

Describe programs to prevent

occupational disease.

5 Avon Metals believes that our employees

are our most valuable asset and we aim to

create clean, safe and sustainable working

conditions. There were no reports of

occupational disease in the reporting

period. The Company promotes a healthy

work-life balance and annual health

screenings are conducted including

monitoring of hearing levels, lung function

and night workers assessment. The

company operates a no smoking policy.

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Performance Indicators—Product Responsibility

PR1 Life cycle stages in which health

and safety impacts of products and

services are assessed for

improvement, and percentage of

significant products and services

categories subject to such

procedures.

8 Pages 43-46 of “Our 20/20 Vision”

Sustainability Report.

PR3 Type of product and service

information required by

8 Adequate information is given to customers.

Avon Metals does not produce end-

SDI 20

GLOBAL REPORTING INITIATIVE (GRI)

Training & Awareness All training is carried out in line with ISO 9001, ISO

14001 and OHSAS 18001 standards.

Monitoring and Follow-up Audits are carried out in line with our Quality,

Environmental and Health & Safety Standard systems.

Additional Information Key successes – Cast Metals Federation Supplier of the

Year 2007

Risks – REACH legislation, Climate change

Disclosure on Management Approach – Product Responsibility

Goals & Performance Our goal is to make successful value added metal

products in a sustainable manner, without harming

anyone or the environment.

Policy ISO 9001 Quality Management System

ISO 14001 Environmental Management System

OHSAS 18001 Health & Safety system – process started

Organisational Responsibility Our organisational structure is detailed on page 73 of

“Our 20/20 Vision” Sustainability Report.

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 7 0

procedures, percentage of

significant products and services

subject to such information

requirements.

consumer products. Material Safety Data

Sheets are supplied with all our products.

PR6 Programs for adherence to laws,

standards, and voluntary codes

related to marketing

communications, including

advertising, promotion, and

sponsorship.

1 Avon Metals is not targeting end-consumers

in our marketing.

PR7

NC

Total number of incidents of non-

compliance with regulations and

voluntary codes concerning

marketing communications,

including advertising, promotion,

and sponsorship by type of

outcomes.

1 Zero.

PR9 Monetary value of significant fines

for noncompliance with laws and

regulations concerning the

provision and use of products and

services.

1 No significant fines for noncompliance with

laws and regulations concerning the

provision and use of products and services.

Some GRI descriptions are edited for length.

For the complete Sustainability Reporting Guidelines, please visit

www.globalreporting.org.

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Avon Metals’ Directors and Management inspire our people and control resources in

line with our established Quality, H&S and Environmental standards.

The Management is responsible for planning what products to sell and make in the

future, organising the materials and resources necessary to carry out these plans,

motivating others to play an effective part in achieving these plans and monitoring the

progress of these plans to ensure they have been implemented correctly.

The Management Team has a combined industry experience of over a century, and

works closely with our local Business Link and makes full use of their corporate

services such as "the Bridge Process" - a strategic management programme designed

to ensure that as a management group there is involvement, clarity, visibility and

agreement in the direction that the business is travelling.

The company is either accredited or working towards Management Systems for

Quality (ISO 9001), Environment (ISO 14001) and Health & Safety (OHSAS 18001) and

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 7 1

Quality (ISO 9001), Environment (ISO 14001) and Health & Safety (OHSAS 18001) and

is currently conducting a feasibility study on the potential integration of LEAN and Six

Sigma techniques into our manufacturing processes.

LEADERSHIP

Avon Metals’ mantra is “leadership through performance and accountability”.

The direction and vision of the company is spearheaded by the Managing Director,

Steven Munnoch. In 2007 he was made a Director and Chairman of the Contracts

Committee of the MMTA (Minor Metals Trade Association) and he won the Young

Business Person of the Year at the 2007 Citizen & Echo Gloucestershire Business

Awards.

Our rules for leadership: -

� Have an open mind a love for travel

�Good leaders listen as much as they talk

� Good leaders have a positive attitude and inspire people

� Good leaders invest in their mind and body

� A good leader is a student for life

� A good leader respects and values people at all levels

� A good leader builds the entire team

� Good leaders know how to have fun

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STAKEHOLDER ENGAGEMENT – BRIDGING THE GAP

Avon Metals acknowledges our responsibility to contribute to sustainable

development. This requires the company to have a clear understanding of relevant

opportunities where it can make a positive contribution. Where appropriate, this

includes contribution through assuming a sense of leadership. Our stakeholder

engagement works in tandem with our consultation with local communities and

considers the wider, not just neighbouring, communities with which we interact.

In particular, the issues which our stakeholders indicate to be of greatest importance

are:

� Occupational health and safety

� Economic and social sustainability

� Environmental and product stewardship

� Governance and ethics

� Climate change

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 7 2

� Climate change

HOW WE ENGAGE OUR STAKEHOLDERS

In the period of reporting, Avon Metals has continued to communicate with a wide

range of stakeholders – we believe that active civil society engagement is

fundamental to the success of our business. Working in partnership with others in

civil society means we can tackle problems and seek solutions acceptable to all

parties. Skills and resources can be pooled to achieve outcomes none of us could

achieve on our own.

We play an active role within the Minor Metals Trade Association (MMTA) and hold

positions on the Executive Committee. We have also continued to play a leading

advisory role through participation in a number of sector trade associations and

government bodies, including the Aluminium Federation (AlFed); The Institute of

Materials, Minerals & Mining; International Titanium Association; Aluminium

Packaging Recycling Organisation (AluPRO); Cast Metals Federation (CMF); the British

Metals Recycling Association; Gloucester City Council; Gloucester County Council;

Beacon South West and the South West Manufacturing Network.

Avon Metals sponsors the Gloucestershire Wildlife Trust and Slimbridge Wildfowl

and Wetlands Trust on bio-diversity and wildlife projects.

The company is involved in a number of sustainability and corporate governance

initiatives including the UN Global Compact; Global Reporting Initiative & the World

Economic Forum’s Partnership Against Corruption Initiative.

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CONTINUED….

We engage our stakeholders through: -

� One to one dialogue (meeting stakeholders individually)

� Open exchange (round tables with other Beacon companies)

� Open doors (site visits to customer sites)

� Partnerships

Stakeholder engagement at Avon Metals is carried out throughout the year and is

integrated into business decision making processes.

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 7 3

Complementing our stakeholder meetings, Avon Metals’ Directors also meet

regularly with our major shareholders regularly.

At these meetings we discuss matters relating to corporate social responsibility and

sustainability, together with the performance and development of the business.

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Stakeholder

Group

Engagement

method

Engagement

frequency

Key topics

and concerns

Response Reporting

method

Customers Verbal

Electronic

Face to face

Questionnaire

s

Daily Quality

Environmental

Legislation

Commercial

Regular

updates

One to one

Raw material

suppliers

Verbal

Electronic

Daily Commercial

Environmental

Sustainability

Quality claims

Contracts

One to one

Mentoring

Service

providers

Partnership As required

Ad hoc

dialogue

Stability Improvement

in service

Report to

Directors

STAKEHOLDER ENGAGEMENT – BRIDGING THE GAP

CONTINUED….

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 7 4

Trade

Associations

Partnership

Open

exchange

Open doors

Lobbying

As required

Ad hoc

dialogue

Legislation

Membership

Compliance Update

reports

Minutes

Open days

Police Partnership Weekly Stolen Goods

Crime

prevention

Robust

Systems

Report

Suspicions

Direct

Initiatives Partnership

Open

exchange

Open doors

Quarterly PACI

Global

Compact

Reach

Continuous

monitoring

Update

reports

Minutes

Shareholders Verbal Weekly Profit & loss

Cap-Ex

Finance

Assistance

where

required

Weekly

management

meetings

Environment

Agency

Email

Verbal

Site visits

Monthly Emissions

Packaging

waste

Compliance

with

legislation

Open site

Workforce Open Forum

Works Council

Feedback

logs

Daily H&S

Training

Welfare

Continuous

improvement

Published

actions

Cascade

communicatio

n

Management Review

meeting

Daily Raw materials

Future sales

Trading

Production

Operations

Finance

Continuous

improvement

Minutes

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ENVIRONMENTAL DIMENSION SDI 2006 2007 2008 2009 2010 2011

TARGET

Reduction of Carbon Dioxide (mg/m³) SDI 1 31 15.8 2.38 2.38 2.38 < 2

Reduction of Nitrogen Oxide (NOx) SDI 1 31 < 5 2.28 2.28 2.28 < 2

Reduction of Sulphur Oxide mg/m³) SDI 1 N/A 4.1 2.9 2.9 2.9 2.5

Energy consumption Mwh/t of finished product SDI 2 1.61 1.59 1.53 1.48 1.47 < 1.45

Transport cost per tonne delivered product £/t SDI 3 25 27 32 38 37 < 30

ISO 14001 Environmental Management System SDI 4 No Yes Yes Yes Yes Yes

Implementation of REACH regulation SDI 5 N/A N/A Yes Yes Yes Yes

Noise Reduction SDI 6 See page 7 for our noise reduction initiatives

Amount of raw material input that is recycled material SDI 7 70% 75% 74% 76% 76% 75%

Amount of packaging waste recycled (Tonnes) SDI 8 905 666 743 488 435 800

Amount of dross recycled (tonnes) SDI 9 942 1030 1172 654 828 1000

Corporate Partner of Gloucestershire Wildlife Trust &

Slimbridge Wildfowl & Wetlands Trust

SDI 10 No No Yes Yes Yes Yes

A V O N M E T A L S 2 0 / 2 0 V I S I O N S U S T A I N A B I L I T Y R E P O R T 2 0 1 0 P A G E 7 5

Slimbridge Wildfowl & Wetlands Trust

Freshwater consumption M³/t of finished product SDI 11 0.39 0.48 0.46 0.45 0.71 0.40

SOCIAL DIMENSION SDI 2006 2007 2008 2009 2010 2011

TARGET

OHSAS 18001 Standard commenced SDI 12 No No Yes Yes Yes Yes

Number of fatalities SDI 12 0 0 0 0 0 0

Investors In People process started SDI 13 No No Yes Yes Yes Yes

Staff Turnover SDI 13 12% 7% 4% 19% 21% < 10%

Employee costs and benefits £ ‘000s SDI 13 1469 1517 1700 1644 2145 2200

Gloucestershire Ambassadors SDI 14 Yes Yes Yes Yes Yes Yes

Beacon South West member SDI 14 No Yes Yes Yes Yes Yes

AluPRO member SDI 14 Yes Yes Yes Yes Yes Yes

Sponsorship of local sports teams SDI 14 No Yes Yes Yes Yes Yes

Global Compact Signatory SDI 15 No Yes Yes Yes Yes Yes

Partnership Against Corruption Signatory SDI 16 No No Yes Yes Yes Yes

ECONOMIC DIMENSION SDI 2006 2007 2008 2009 2010 2011

TARGET

Defects (products that require re-working) SDI 17 1.80% 1.60% 0.80% 0.78% 0.76% 0.50%

ISO 9001 Quality Management System SDI 17 Yes Yes Yes Yes Yes Yes

Financial contribution to the local economy £ ‘000s SDI 18 1890 2987 2761 1000 1647 3000

Research & Development SDI 19 See page 23 for savings made through R & D.

Global Reporting Initiative Signatory SDI 20 No No Yes Yes Yes Yes

MANAGEMENT & LEADERSHIP DIMENSION SDI 2006 2007 2008 2009 2010 2011

TARGET

Awards & Accreditations Received M & L 1 7 2 8 3 3

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AWARDS & ACCREDITATIONS

Avon Metals is an entrepreneurial forward thinking company, and as such we rarely get

chance to reflect on the past.

However, it is always nice to have success acknowledged by our peers and over the past

few years we have received a plethora of prestigious environmental, social & economical

awards in recognition of our achievements.

2010

�Major Commendation: BCE Environmental Leadership Awards

�Highly Commended: Environmental Efficiency , EEF Future Manufacturing Awards

�Runner-up: Innovative People Practices, EEF Future Manufacturing Awards

2009

�Winner: The Queen’s Awards for Enterprise: Sustainable Development

�Finalist : ITV / Price Waterhouse Coopers West of England Business Awards

�Finalist : Business of the Year, Gloucestershire Business Awards

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�Finalist : Business of the Year, Gloucestershire Business Awards

�Finalist : Corporate Social Responsibility, Gloucestershire Business Awards

�Finalist : SME Manufacturer of the Year, The Manufacturer Awards

�Finalist : Sustainable Manufacturing, The Manufacturer Awards

�Finalist : Business Growth Award, EEF Future Manufacturing Awards

�Finalist : Environmental Achievement Award, EEF Future Manufacturing Awards

2008

�Finalist : Best SME in “The Manufacturer Awards” – winner announced October 2008

�Finalist : Best Company in the Gloucestershire Business Awards

�Finalist : ITV / Price Waterhouse Coopers West of England Business Awards

2007

�Winner : The Queen’s Award for Enterprise: International Trade.

�Winner : International Trade Award in the Gloucestershire Business Awards

�Winner : Steven Munnoch, Young Business Person of the Year in the Gloucestershire

Business Awards

�Winner : Cast Metals Federation Supplier of the Year

�Winner : Gloucestershire Ambassador’s Book Check Cup for outstanding contribution

to the region

�Accredited : ISO 14001 Environmental Management System

�Accredited : Beacon South West Status

2006

�Runner Up : Valpak Awards, Best Investment of PRN Revenue

�Avon Metals is also proud to have featured in the top half of the Top 100 companies in

Gloucestershire in 2007 & 2008.

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ORGANISATIONAL STRUCTURE

Avon Metals believes that every single one of our employees is central to the delivery of

our sustainability strategy.

Chairman

Managing

Director

Operations

Director

Commercial

Executive

Commercial

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Commercial

Co-ordinators

X 2

Raw Materials

Buyer

Financial

Controller

Admin x 1Book-

Keeper

Logistics

Manager

Drivers x 2Admin

Packing x 5

Dispatch

Raw

Materials

Manager

Goods In x 4

Yard x 3

Warehouse x

2

Engineering

Manager

Fitter

Laboratory

Manager

Lab

Technicians x

2

Production

Manager

Shift

Supervisors x

2

Foundry men

x 13

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CONTACT US

MAILING ADDRESS

Avon Metals Ltd

Ashville Works

Ashville Road

Gloucester

GL2 5DA

England

TELEPHONE

+ 44 (0) 1452 529696

FACSIMILE

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+ 44 (0) 1452 300624

E-MAIL

[email protected]

Thank you for sharing in “Our 20/20 Vision.”.

Stakeholder feedback is very important to us, and we welcome comments, questions

and suggestions to be sent to us via the above contact details.

www.avonmetals.com

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